EPA 910/9-80-077-
United States
Environmental Protection
Agency
Region'TO"
1200 Sixth Avenue
Seattle WA 98101
Water
August 1981
EPA-10-WA-KING-Metro-WWTW-81
Environmental
Impact Statement
Final
Wastewater Management Plan
For the
Lake Washington/Green River Basins
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U.S. ENVIRONMENTAL PROTECTION AGENCY
57-4, REGION X
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
^PRO^°
ATTNYO° M/S 443
JUL 2 9 1981
TO: All Interested Government Agencies, Public Groups, and Citizens
I am forwarding for your review and comment this final environmental
impact statement (EIS) on the Wastewater Management Plan for the Lake
Washington/Green River Basins. The Environmental Protection Agency
(EPA) has given the Municipality of Metropolitan Seattle (Metro) a grant
for planning needed facilities for treatment and disposal of wastewater
from the Renton study area. Metro is expected to apply to EPA for a
grant for construction of approved facilities, under Section 201 of the
Federal Clean Water Act. EPA has prepared this EIS on its proposed
approval of Metro's facilities plan, pursuant to Section 102(2)(c) of
the National Environmental Policy Act of 1969 and implementing Federal
regulations.
EPA will announce the availability of this document in the Federal
Register on Friday, August 14, 1981, beginning a 30-day review period.
If you have any comments on this final EIS or wish to provide additional
information, we would appreciate hearing from you before the close of
the comment period on September 14, 1981. All comments will be used by
EPA in evaluating the effects of approving the proposed plan. Please
send your comments, or requests for additional copies of the draft EIS
to:
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Additional copies of this document and supporting appendices are available
for review at the EPA Region 10 Library at the above address; at the
Metro Library at 821 Second Avenue, Seattle; and at public libraries at
Bellevue, Burien, Redmond, and Renton.
Public hearings are scheduled for September 8, 9, and 10 in Bellevue,
Alki, and Highline. Locations and times are listed on page ix. I hope
you will take the time to give us your views either in writing or at a
hearing.
Sincerely,
*» -*•- .
L. Edwin Coate
Deputy Regional Administrator
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ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER MANAGEMENT PLAN FOR THE
LAKE WASHINGTON/GREEN RIVER BASINS
Prepared by
U. S. Environmental Protection Agency
Region 10
Seattle, WA 98101
With Technical Assistance from
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, CA 95816
Responsible Official:
~ - ^^ "~T^~ ~ ~" -— • af
L. Edwin Coate
Deputy Regional Administrator
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TABLE OF CONTENTS
FOREWORD
EPA Proposed Action
Rationale for the Proposed Action
Rationale for Centralized Treatment Plant
Rationale for Deferring North Service
Area Decisions iii
Rationale for Diverting Discharge from
Duwamish River to Puget Sound iii
Rationale for Alternative Puget Sound
Discharge Locations iv
Proposed Grant Conditions v
The Effect of Public Involvement vii
General Responses to Most Frequent Comments
on Draft EIS ix
Wastewater Management Planning Issues xiii
Sensitive Areas Issues xiv
Construction Impact and Neighborhood
Issues xvi
Cost Issues xvii
EPA Decision-Making Issues xx
SUMMARY xxv
Purpose and Need for Action xxv
Description of Alternatives xxvi
Background xxvi
Long-Term Wastewater Management
Alternatives xxvi
Other Aspects of the Final Wastewater
Management Plan xxviii
Near-Term Collection System Projects xxviii
Nonsewer Area xxviii
Triggering Mechanism xxviii
Sludge Disposal xxviii
Alternatives Available to EPA xxviii
Assessment of Impacts xxix
Impacts of Final Plan Recommended Program
and Mitigation Measures xxix
Comparison of Alternatives xxxiv
Alternatives A-3/A-5 xxxviii
Alternative A-l xxxviii
Alternative B-l xxxviii
No-Project Alternative xxxix
Impacts Common to All Alternatives xxxix
Public Involvement xxxix
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CHAPTER 1 - INTRODUCTION 1
Metro's Wastewater Management Plan 1
Development of the Wastewater Management
Plan 1
EIS Context 3
Major Issues Addressed by EIS 3
National Environmental Policy Act of 1969
(NEPA) Requirements 4
EIS Chronology 5
Subsequent EIS Activities 5
Public Participation 5
Institutional Considerations 6
Laws, Policies, and Agencies Affecting
the EIS 6
Clean Water Act 6
Clean Air Act 7
Endangered Species Act 7
Fish and Wildlife Coordination Act 7
National Historic Preservation Act 8
Archeological and Historic Preservation
Act 8
Coastal Zone Management Act 8
EPA Policy on Agricultural Lands
Protection 9
EPA Policy on Floodplain and Wetlands
Protection 9
Affected Agencies and Their Jurisdictions 9
Environmental Protection Agency 0
Corps of Engineers 12
Department of Ecology 12
Departments of Fisheries and Game 12
Department of Natural Resources 12
Puget Sound Council of Governments 12
Metro 12
Counties and Cities 12
Special Districts 13
Existing Sewerage Facilities 13
The Study Area 13
Study Area Wastewater Collection Systems 13
The Renton Treatment Plant 17
Wastewater and Sludge Characteristics 21
Wastewater 21
Sludge 24
Existing Chemical Consumption 24
Existing Energy Use 27
Existing Costs of Wastewater Treatment 29
The Nonsewer Area 29
CHAPTER 2 - DESCRIPTION OF RECOMMENDED PROGRAM
AND EIS APPROACH 31
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- Introduction 31
Process for Selecting Recommended Program 31
Description of the Recommended Program 32
Effluent Stream 34
Solids Stream 34
Effluent Disposal 37
Costs and Financing 37
Alternatives for the Nonsewer Area 41
Triggering Mechanism 43
Near-Term Collection System Projects 44
Approach to EIS Evaluation of Recommended
Program and Alternatives 44
Program Elements Evaluated 44
Differences in Impacts Between Recommended
Program and Alternative A-3 46
CHAPTER 3 - DESCRIPTION OF AFFECTED ENVIRONMENT 49
Climate and Air Quality 49
Climate 49
Air Quality 50
Soils, Geology, and Groundwater 50
Soils 50
Geology and Groundwater 54
Water Resources and Water Quality 57
Inland Surface Water 57
Puget Sound 57
Biology 61
Terrestrial Biology 61
Aquatic and Marine Biology 61
Fisheries 61
Species and Habitats of Special Interest 63
Land Use and Socio-Economics 63
Land Use 63
Population and Housing 65
Regional Economy and Employment 65
Public Services Provision 67
CHAPTER 4 - DESCRIPTION OF ALTERNATIVES 69
Introduction 69
Long-Term Alternatives for Sewer Service Area 69
Flow Projections and Service Area 69
Description of 15 Initial Alternatives 71
Other Long-Term Alternatives for the
Sewer Service Area 71
Alternatives Considered and
Rejected by Metro 71
The No-Project Alternative 78
Description of Screening/Selection Process
and Final Alternatives 79
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The Selection Process 79
Expanded Description of Final Alternatives 80
Alternative A-l 80
Alternative A-3 84
Alternative A-5 86
Alternative B-l 87
Collection System Changes 89
Wastewater Treatment 92
Solids Handling 92
Effluent Disposal 94
Solids Disposal Alternatives and Costs 97
Current Sludge Disposal Methods 97
Identification of Options 98
Ocean Disposal 98
Conventional Incineration 99
Coincineration 99
Sanitary Landfill 99
Silviculture 99
Soil Improvement 100
Composting 100
Agricultural Use 100
Selection of a Recommended Program 100
CHAPTER 5 - CONSTRUCTION AND SITE-RELATED IMPACTS
OF ALTERNATIVES 103
Overview 103
Impacts of Alternatives A-3/A-5 103
Collection System Changes 105
Redmond Connection 105
North Creek/Hollywood Connection 107
Renton Treatment Plant Expansion 108
Description of Existing Environment 108
Assessment of Impacts 109
Solids Handling Facilities 112
Tunnel/Outfall 113
Description of Existing Environment 113
Assessment of Construction Impacts 117
Summary of Major Construction and Site-
Related Impacts of Final Plan Recommended
Program and Mitigation Measures 126
Impacts of Alternative A-l 128
Differences from Alternatives A-3/A-5 128
Nitrification Facilities 128
Additional Land Required for Solids
Handling Facilities 128
Impacts of Alternative B-l 130
Difference from Alternatives A-3/A-5 130
Changes at the Renton Treatment Plant
Site 131
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Kenmore Treatment Plant 131
Kenmore Treatment Plant Outfall 131
Construction Employment Impacts 133
CHAPTER 6 - OPERATIONAL IMPACTS OF ALTERNATIVES 137
Introduction 137
Water Quality, Aquatic Biology, and Fisheries 137
Introduction 137
Water Quality 138
Background 138
Impacts of Alternatives A-3/A-5 on
Puget Sound 144
Impacts of Alternatives A-3/A-5 on
Green/Duwamish River 169
Impacts of Redmond Connection
Emergency Bypass 176
Impacts of Alternative A-l 177
Impacts of Alternative B-l 184
Impacts of No-Project 184
Aquatic Biology and Fisheries 185
Background 185
Impacts of Alternatives A-3/A-5 187
Impacts of Alternative A-l 188
Impacts of Alternative B-l 190
Impacts of No-Project 190
Mitigation Measures 191
Short-Term Water Quality and Aquatic
Biology Impacts During Project Design
and Construction 192
Resource Use 193
Energy Use 193
Chemical Use 196
Mitigation Measures 198
Growth-Related Impacts Resulting from Staging
of Alternatives 198
Background 198
Impacts of Alternatives A-3/A-5 199
Overall Flexibility 199
Potential Impacts of the Renton
Outfall Tunnel and Redmond Connection 199
Impacts of Alternative A-l 201
Impacts of Alternative B-l 201
Impacts of No-Project 201
Mitigation Measures 201
Reduce Staging Period 202
Base 50-Year Flow Projections on Land
Use Plans or PSCOG Forecasts 202
Recreation Opportunities 202
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Page
CHAPTER 7 - SECONDARY IMPACTS COMMON TO ALL
ALTERNATIVES 205
Introduction 205
Relation of Wastewater Alternatives to
Growth and Secondary Impacts 205
Local Recognition of Relationship
Between Sewerage Availability and
Growth 205
Growth and Secondary Impacts of a
No-Project Alternative 206
Growth and Secondary Impacts of the
Recommended Program 207
Assumptions for Secondary Impact Assessment 207
Contents of Chapter 208
Description and Assessment of PSCOG' s Population
Projection 208
Method 208
Projected Population 209
Critique 210
Comparison of PSCOG Forecast to Other
Forecasts 212
EPA Grant Regulations Relating to
Population Forecasts 212
The Bureau of Economic Analysis (BEA)
Projections 212
Status of BEA Projections in the
State of Washington 212
Multiplicity of County and Regional
Forecasts • 213
Secondary Air Quality Impacts 216
Background 216
Assessment of Impacts 216
Mitigation Measures' for Air Quality Impacts 218
Secondary Surface Water and Biological Impacts 218
Secondary"Surface Water Quality Impacts 218
Background 218
Water Quality Impacts of Urban Runoff 219
Water Quality Impacts of On-Site
Systems 221
Secondary Impacts on Aquatic Biology and
Fisheries 221
Background 221
Streams 223
Lakes 228
Mitigation Measures for Water Quality and
Fisheries Impacts 228
RIBCO Studies 229
Metro 208 Plan 229
Local Plans and Policies 230
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Shoreline Management Act 230
Summary 230
Secondary Impacts on Terrestrial Ecosystems 230
Secondary Groundwater Impacts 231
Background 231
Treatment Capability of Local Soils 231
Major Contaminants of Concern 321
Assessment of Impacts 232
Analysis of Septic Tank Failure Data 232
Risks to Groundwater 233
Mitigation Measures for On-Site Systems 234
Metro-Proposed Measures 234
Determine Groundwater Carrying Capacity 235
EPA Role 235
Secondary Land Use Impacts 236
Consistency of the Metro Service Area With
Local Land Use Policies 236
Prime Farmland Conversion 237
Background 237
Assessment of Impacts 241
Mitigation Measures for Prime Farmland
Conversion 244
Impacts on Sensitive Areas 247
Background 247
Assessment of Impacts 247
Public Service Systems 254
Wastewater Management 254
Existing Management System 254
Existing Capacity Problems 255
Impacts of Growth 255
Water Supply 255
Existing Management System 255
Existing Capacity Problems 257
Impacts of Growth 257
Drainage and Flood Control 258
Existing Management System 258
Existing Capacity Problems 258
Impacts of Growth 258
Solid Waste Management 259
Existing Management System 259
Existing Capacity Problems 259
Impacts of Growth 259
Recreation 259
Existing Management System 259
Existing Capacity Problems 259
Impacts of Growth 260
Social Services 260
Existing Management System 260
Existing Capacity Problems 260
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Impacts of Growth 260
Transportation 261
Existing Management System 261
Existing Capacity Problems 261
Impacts of Growth 261
Electricity and Gas 261
Existing Management System 261
Existing Capacity Problems 263
Impacts of Growth 263
Mitigation Measures for Public Services
Impacts 263
Comprehensive Plans 263
Wastewater Management Plans 263
Water Supply 263
Drainage and Flood Control 263
Solid Waste Management 263
Transportation 263
Secondary Impacts on Public Finance 264
Background 264
Responsibility for Provision of Services 264
Fiscal Outlook of the Study Area 265
Mitigation Measures for Fiscal Impacts 267
CHAPTER 8 - EPA ALTERNATIVES AND PROPOSED ACTION 269
EPA Alternatives 269
Overview 269
New Structural Alternatives 269
Administrative Alternatives: Approval
and Funding 270
Approve and Fund One Alternative 270
Approve and Fund No Alternative 271
Approve and Fund More than One
Alternative 271
Funding of Project Phases 272
Funding Beyond the 20-Year Capacity 272
Administrative Alternatives: Grant
Conditions 272
Proposed Action 273
Evaluation of Alternatives 273
Selection of the Preferred Action 275
Rationale for Key Trade-Offs 276
Rationale for Centralized Treatment
Plant 276
Rationale for Deferring North Service
Area Decisions 276
Rationale for Diverting Discharge from
Duwamish River to Puget Sound 277
Rationale for Alternative Puget Sound
Discharge Locations 277
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Proposed Grant Conditions 278
CHAPTER 9 - COORDINATION 283
Introduction 283
Public Participation 283
Information Brochure 283
Scoping Meeting 283
Notice of Intent 284
Presentation to Wastewater Plan Citizens
Advisory Committee 284
Public Meeting on Alternatives 284
Public Meetings on Preliminary Plan 285
Public Meetings and Hearings on Draft
Plan and EIS 285
Written Comments on Draft EIS 286
Schedule for Remaining EIS and Plan Activities 286
CHAPTER 10 - LIST OF EIS PREPARERS 293
Jones & Stokes Associates, Sacramento, CA 293
Clean Water Consultants, Santa Ana, CA 294
Gruen Gruen + Associates, San Francisco, CA 294
H. Esmaili & Associates, Berkeley, CA 295
Kahn/Mortimer Associates, Seattle, WA 296
Hall and Associates, Seattle, WA 296
University of Washington, Office of Public
Archeology, Seattle, WA 296
University of Washington, Fisheries Research
Institute, Seattle, WA 296
G-ological Drafting Service, Sacramento, CA 297
CHAPTER 11 - BIBLIOGRAPHY 299
CHAPTER 12 - WRITTEN COMMENTS RECEIVED ON DRAFT EIS
AND RESPONSES TO COMMENTS 315
Introduction 315
Federal Agencies 316
State Agencies 328
Regional and Local Agencies 345
Organizations 376
Citizens 399
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LIST OF TABLES
Table Page
S-l Summary of Major Impacts and Mitigation
Measures for Final Plan Recommended Program xxx
S-2 Summary Comparison of Major Environmental Impacts:
Wastewater Management Alternatives for the
Lake Washington/Green River Basins xxxv
1-1 Institutional Overview: Lake Washington/Green
River Basins 10
1-2 Renton Study Area Local Sewerage Agencies 14
1-3 Existing and Proposed Discharge Limitations for
the Renton Wastewater Treatment Plant 18
1-4 Influent and Effuent BOD and SS Quantities 23
1-5 Renton Treatment Plant Effluent Characteristics 25
1-6 Costs of Wastewater Treatment at the Renton Plant 30
2-1 Liquid Stream Design Parameters, 30/30 Effluent 35
2-2 Renton Solids Facilities Design Parameters 36
2-3 General Tunnel/Outfall Information 39
2-4 Cost of Recommended Improvements 40
2-5 Near-Term Collection System Projects 45
3-1 Use and Limitations of Some Dominant Soils in
the Renton Study Area 53
3-2 Lake Use Ratings 59
3-3 River and Small Stream Use Ratings 60
3-4 Historic Population Trends, Counties and Major
Cities, 1930-1970 66
4-1 Description of 15 Initial Long-Term Alternatives 72
4-2 Potential Treatment Plant Flow Reduction Measures 77
4-3 Metro Rating of Initial Alternatives Against the
ALCA to Identify Potential Overriding Benefits 81
4-4 Costs for Redmond Connection and North Creek/
Hollywood Connection - Alternatives A-3/A-5 90
4-5 Costs for Renton Treatment Plant Improvements -
Alternatives A-3/A-5 93
4-6 Cost Comparison of Alternative Effluent Discharge
Routes 95
4-7 Costs of Candidate Sludge Disposal Systems 101
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Table Page
5-1 Overview of Construction and Site-Related Impacts
of Project Components 104
5-2 Existing Land Uses for Tunnel and Open-Cut
Alignments 115
5-3 Comparative Lengths of Tunnels 122
5-4 Summary of Major Construction/Site Impacts and
Available Mitigation Measures for Final Plan
Recommended Program 127
5-5 Total Employment Impacts of Project Alternatives 134
5-6 Employment Impacts of Project Alternatives, by
Phase 135
6-1 Estimated Influent and Effluent Concentrations from
Proposed Treatment Plants in the Lake Washington/
Green River Basins Study Area 145
6-2 Vertical Density Differences (200 feet vs. surface)
at Three Tree Point and Alki Point 148
6-3 Predominate Directions of Winds Greater than
10 mph at Sea Tac Airport 159
6-4 Pollutant Loading Summary of Renton Alternatives
and NPDES Data for Puget Sound Discharges
from Alki Point South 161
6-5 Effect of Renton Effluent on Heavy Metals Con-
centrations in ug/1, in Puget Sound 165
6-6 Estimate of Yearly Copper, Lead and Zinc Input to
Puget Sound for a Renton Plant Discharging at
100 MGD, Compared to Other Sources at Present
Levels 167
6-7 Effluent Limits Estimated by DOE to Protect Water
Quality and Average Existing Effluent Concen-
trations for the Renton Discharge 182
6-8 Interim Measures to Reduce Ammonia Loading to the
Duwamish River 194
6-9 Estimated Energy Requirements for Proposed Alter-
natives 195
6-10 Estimated Chemical Requirements (tons per year) 197
6-11 Long-Term Peak Flow Projections Used to Size
Renton Outfall Tunnel and Redmond Connection 200
6-12 Potential Recreation Opportunities Provided by
Long-Term Alternatives 203
7-1 Projected Population Increase by Drainage Basin,
Renton Study Area, 1980-2000 211
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Table Page
7-2 Washington State Population Forecasts and
Projections 214
7-3 Comparison of Regional and King County Population
Forecasts 215
7-4 Comparison of September 1978 and May 1979 PSCOG
Population Forecasts for the Three-County Puget
Sound Air Quality Planning Region 217
7-5 Nonpoint Source Pollutant Loading Estimates for
Land Use Types in Locations near Kent, Washington 220
7-6 Increase in Urban Acres by Subdrainage Basin,
1980-2000 227
7-7 Forecast of Prime Farmland Conversion 243
7-8 Prime Agricultural Land Mitigation Matrix 245
7-9 PSCOG Projections of Sewered Urban Acres by
Subdrainage Basin, 1980-2000 256
7-10 Projected Home-Work/College Trips by Place of
Residence and Place of Work 262
9-1 Mailing List for Final EIS 287
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LIST OF FIGURES
Figure Page
1-1 Study Area Boundaries 2
1-2 Component Agencies in the Renton Study Area 15
1-3 Local Service Areas, Existing Sewer Service Areas
and Metro Collection System 16
1-4 Process Schematic of Renton Treatment Plant 19
1-5 Renton Treatment Plant Wastewater Flows 22
1-6 Pounds of Sludge Pumped to West Point 26
1-7 Renton Treatment Plant Electric Power Cost vs. Time 28
2-1 Recommended Renton Service Area 33
2-2 Proposed Tunnel/Outfall Route 38
2-3 Estimated Future Metro Monthly Rate (Assuming Metro
Receives 33% of Available Statewide Funds) 42
3-1 Relative Contribution of Emission Sources - 1977
Inventory 51
3-2 General Soil Associations 52
3-3 Schematic Hydrogeologic Sections of the Lake
Washington/Green River Basins 55
3-4 Major Surface Water Bodies in the Study Area Showing
Salmon Use 58
3-5 Terrestrial Habitat of Lake Washington/Green River
Basins 62
3-6 Urba-n Land Uses in the Lake Washington/Green River
Basins, 1975 64
4-1 Service Areas 70
4-2 Alternative A-l 82
4-3 Alternatives A-3/A-5 (Preferred Program) 85
4-4 Alternative B-l 88
4-5 Alternative Effluent Discharge Routes 96
5-1 Alignment of Redmond Connection and North Creek/
Hollywood Connection' 106
5-2 Renton Treatment Plant Layout: Recommended Program 110
5-3 Location of Subsurface Corings at Renton Treatment
Plant Site 111
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Figure
5-4 Alternative Effluent Discharge Routes
5-5 East Tunnel Portal
5-6 West Tunnel Portal
5-7 Renton Treatment Plant Layout: Alternative A-l
5-8 Kenmore Treatment Plant Schematic: Alternative
B-l (Conceptual 40-Acre Site) 132
6-1 Subdivisions of Puget Sound 140
6-2 Shellfish Resources Near Potential Discharge Areas 141
6-3 Lower Green-Duwamish River with River Mile Index 143
6-4 Tidal Current Direction and Typical Velocities
Near Alki Point 149
6-5 Tidal Current Direction and Typical Velocities
Near Three Tree Point (Point Pulley) 150
6-6 Surface Current Directions in Central Puget Sound
as Determined by University of Washington Puget
Sound Model 151
6-7 Surface Current Studies off Alki Point 154
6-8 Current Studies off Alki Point 155
6-9 Current Studies off Seahurst Park 156
6-10 Current Studies off Three Tree Point (Point Pulley) 157
6-11 Surface Sediments of Puget Sound in Vicinity of
Alternative Discharge Areas 168
6-12 Effects of Renton Treatment Plant Alternatives
on Dry Seasonal Freshwater Flows in Green-Duwamish
Estuary 170
6-13 Observed Longitudinal Profiles of Salinity,
Temperature, and Dissolved Oxygen Concentration
in the Duwamish River Estuary During the Low
High Tide of September 13, 1968 171
6-14 Mean Daily Freshwater Inflow, Tidal-Prism Thickness,
and Minimum Bottom DO, at Station 7.8, June-
September 1966 172
6-15 Ammonia Concentration at 16th Avenue So., Surface
During June to September 173
6-16 Frequency Comparison of Palmer Flows for Tacoma
Demands of 76 and 144 MGD 175
6-17 Field Data and Mathematical Modeling Results for
Dissolved Oxygen in Green-Duwamish River 180
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Figure Pagt
7-1 Historical, Current and Projected Phosphorus
Loading to Lake Washington 222
7-2 Relationship Between Urbanization and Clean
Water Stream Insects (Percent Ephemeroptera,
Plecoptera, Trichoptera) in Renton Study Area 224
7-3 Urbanization Impacts on Salmonid Fishery Resources 225
7-4 Map of SCS Important Farmlands and of King County
Agricultural Districts 239
7-5 Location of High Growth Subdrainage Basins 248
7-6 Composite Map of Sensitive Areas Within Study Area 249
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FOREWORD
This Final Environmental Impact Statement (EIS) has
been prepared by the U. S. Environmental Protection Agency
(EPA) to describe the environmental impacts associated with
EPA's proposed approval of the Municipality of Metropolitan
Seattle (Metro) Final Wastewater Management Plan for the
Lake Washington/Green River Basins. The Final EIS has been
prepared pursuant to the National Environmental Policy Act
of 1969 and implementing federal regulations.
EPA's objective in taking action on Metro's Wastewater
Management Plan is to assist Metro in meeting the require-
ments of its state wastewater discharge permit, and thereby
work toward achieving the goals of the federal Clean Water
Act. EPA will provide financial assistance to implement
an approved plan, based on the plan's cost-effectiveness
and environmental acceptability.
EPA previously circulated a Draft EIS on Metro's Draft
Wastewater Management Plan. Comments on the Draft EIS were
received during a 60-day review period extending from
December 19, 1980 to February.17, 1981. Five public meetings
and two public hearings were held in January 1981 to receive
comments from citizens, organizations, and agency staffs.
Based on public and agency comment, and additional environ-
mental analysis, EPA has identified a proposed EPA action
which is the subject of this Final EIS.
EPA Proposed Action
EPA proposes to approve for federal funding a long-
term wastewater management program for the Renton study area,
including expansion of the Renton treatment plant's secondary
treatment capacity to 72 MGD by the year 1990, construction
of solids handling facilities at the Renton treatment plant
site, and construction of a tunnel and outfall for discharge
of treated effluent to Puget Sound.
Metro's draft plan considered two alternative locations
for the Puget Sound outfall: Alki Point and Seahurst Park.
EPA finds that, based on environmental criteria alone, ex-
cluding costs, Alki Point is an environmentally preferable
discharge location. This is due to the greater circulation
of Puget Sound waters off Alki, compared to Seahurst, which
allows much more rapid dispersion of effluent off Alki. This
is important in relation to concern about long-term water
quality trends in Puget Sound, especially in shallower embay-
ments.
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A plan including a Seahurst outfall has a present net
worth cost which is $66 million less than the cost of a plan
with an Alki outfall. This EIS has concluded, based on all
available information, that no major adverse impacts to Puget
Sound can be predicted with a Seahurst outfall. Therefore,
EPA considers a plan with a Seahurst outfall to be the cost-
effective alternative, and to be environmentally acceptable.
From a technical standpoint, EPA has been unable to
conclude that the environmental advantages of the Alki site
represent overriding concerns. Such a conclusion would be
necessary for EPA to approve an alternative other than the
cost-effective alternative. However, this is largely because
little can be conclusively stated about long-term cumulative
impacts to Puget Sound, especially to the area south of Alki
Point, from major municipal discharges. Therefore, the con-
clusion as to possible overriding benefits of an Alki dis-
charge is to a great extent a judgement about the desired
degree of risk avoidance in the face of poorly known future
conditions. An Alki discharge would provide a greater degree
of certainty that long-term problems would be avoided.
EPA believes that the judgement as to the desired level
of risk-avoidance is a decision in which local citizens,
acting through their elected officials on the Metro Council,
should have a major voice. EPA will therefore make a final
decision on potential overriding benefits of an Alki discharge,
based on the decision of the Metro Council. If the Metro
Council selects a plan with a Seahurst discharge location,
and that plan is certified as acceptable by the Washington
Department of Ecology, EPA would approve that plan for
federal funding. If the Metro Council concludes that the
relative advantages of the Alki discharge location are over-
riding considerations, and selects a plan with an Alki dis-
charge location, and DOE certifies that plan, EPA would con-
sider that as persuasive evidence that Alki has overriding
benefits and would approve that plan for federal funding.
Due to severe constraints on the availability of federal
grant funds for wastewater treatment facilities, EPA does
not predict that additional federal funds will be available
for an Alki plan beyond what would be available for a Seahurst
plan. Therefore, the cost increase of the Alki plan would
have to be assumed by state and/or local sources.
Regardless of the selected outfall location, EPA believes
that there is a need for additional studies as part of the
design of the selected route, and for monitoring of outfall
performance and Puget Sound water quality conditions. Various
grant conditions and recommendations are presented below
which address these concerns.
11
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Rationale for the Proposed Action
Rationale for Centralized Treatment Plant
A centralized plant configuration was found to be less
expensive in most cases than a dual configuration including
both Renton and Kenmore plants. A centralized system also
avoids the construction impacts of a new plant and an addi-
tional tunnel and outfall. Further, it reduces the potential
for effluent contact with more than one recreational beach
area. Although addition of a Kenmore plant and outfall in-
creases overall system reliability and may decrease potential
long-term effects on Puget Sound or Elliott Bay, these con-
siderations were not felt to counter-balance the advantages
of a centralized system. No major differences between the
two configuration strategies were found in the areas of water
quality standards, fisheries, or seismic hazards.
Rationale for Deferring North Service Area Decisions
The proposed action would defer the decision on the
issue of where to treat future wastewater flows from the
North Lake Washington/Lake Sammamish area. That area is
presently connected to Metro's West Point plant. Although
a decision now would provide greater public certainty about
future conditions, a deferred decision offers the possibility
of substantial cost savings and a more logical overall waste-
water system. Adding the north service area to the Renton
system would provide a greater proportion of secondary treat-
ment for regional wastewater. However, leaving that area
in the West Point system, in addition to avoiding the costs
and impacts of connection facilities and greater operation
and maintenance costs, provides more flexibility to respond
to changes in service area growth, and discharges more effluent
in northward-flowing waters of Puget Sound.
Rationale for Diverting Discharge from Duwamish River to
Puget Sound
The overriding factor favoring diversion from the Duwamish
River is the ability to avoid water quality standards violations
and possible losses to the valuable salmon fishery and to
bottom fish. These problems would exist even if nitrification
is added to the treatment process. There will not be water
quality standards or fisheries problems with a Puget Sound
discharge. On the other hand, diversion entails construction
impacts from the tunnel and outfall, the possibility of diluted
effluent contacting popular recreational beaches, and the
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need to construct nonmodular facilities sized for 50-year
loads. No major differneces were found in the area of cost,
assuming a Seahurst discharge, or in the area of long-term
Puget Sound impacts. Overall, the judgement of EPA decision
makers is that the water quality and fishery concerns,
especially considering the greater possibility of plant
upset with more sophisticated treatment, outweigh the
relatively short-term construction impacts, and the possi-
bility of effluent contacting beaches. No adverse impact
to the beneficial uses of beaches is expected from occasional
contact with diluted effluent.
Rationale for Alternative Puget Sound Discharge Locations
A Seahurst discharge would experience occasional periods
of several days or more of very poor dispersion in which
diluted effluent would remain in the central East Passage
area, before moving south. Some effluent would probably
move into Commencement Bay and south Puget Sound before
exiting north through Colvos Passage. With an Alki discharge,
there would probably be good dispersion to the north within
a few days under all tidal conditions, with little movement
of effluent south of Alki Point. An Alki discharge would
therefore offer greater protection against any possibility
that diluted effluent might contribute over time to cumulative
impacts to Puget Sound south of Alki. It is not presently
predicted that cumulative impacts could be expected with
a Seahurst discharge, but little conclusive information
exists as a basis for prediction.
A plan with a Seahurst outfall would be $66 million
less expensive, in present net worth terms, than a plan with
an Alki outfall. The Seahurst route also would have slightly
less construction impact than the Alki route. Although the
Alki route has a shorter tunnel length, it would require
over 10 miles of open cut construction and would involve
more neighborhood disruption. An Alki route has the advan-
tage of providing opportunities for cost sharing with com-
bined sewer overflow control projects, if such projects were
undertaken.
The Alki and Seahurst outfall locations appear to be
largely equivalent in terms of public health concerns, fisheries
water quality standards, reliability, and seismic or landslide
hazards. Overall, the choice seems to be whether the greater
long-term risk-avoidance of an Alki discharge is worth its
greater cost.
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Proposed Grant Conditions
The following grant conditions are intended by EPA to
mitigate certain potential adverse impacts identified in
this EIS. Several are intended to provide for additional
study after selection of the preferred plan. These include
conditions concerning additional cultural resources, geo-
technical, and oceanographic studies; a construction site
plan and site restoration plan; a spoils disposal plan; and
a monitoring plan. Other conditions pertain to project con-
struction timing, to ensure that discharge facilities are
completed prior to the onset of major new outputs from treat-
ment facilities. Another condition is intended to meet EPA
policies on agricultural lands, floodplains, and wetlands,
while affirming the authority of local land use agencies
over land use planning decisions.
Several additional recommendations are also made which
encourage implementation of various ongoing studies.
Proposed grant conditions are as follows:
1. Prior to construction Metro shall ensure that an
historical/archeological survey is conducted for
the selected tunnel/outfall route and at any other
construction sites other than the Renton treatment
plant. The results of the survey shall be sent
to the State Historic Preservation Officer (SHPO).
Any subsequent recommendations by the SHPO shall
be formally considered in accordance with require-
ments of Section 106 of the National Historic Pre-
servation Act. Any SHPO recommendations shall be
forwarded to EPA. If cultural resources are dis-
covered during construction at the Renton treatment
plant, construction shall stop until a professional
archeologist has assessed the significance of the
resources.
2. Prior to construction, Metro shall prepare and
submit to EPA and the Washington State Department
of Ecology its proposed water quality monitoring
plan for the Renton Puget Sound discharge. The
monitoring plan shall include at least the proposed
parameters to be measured, sampling locations and
sampling frequency. EPA and DOE shall have the
opportunity to review and comment on the proposed
monitoring plan.
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3. During predesign work, Metro shall conduct detailed
geotechnical and oceanographic studies of the selected
tunnel/outfall location. The scope of work for
these studies shall be made available to the public
and shall be submitted to EPA and DOE. These studies
shall include, at a minimum, an identification and
assessment of soil instability and seismic hazards
along the route, baseu on SILG specific investigations,
and development of siting or construction methods
to reduce risks to acceptable levels. The results
of the detailed studies shall be reported in a docu-
ment which will also be available to the public
and submitted to EPA and DOE for review. Metro
shall hold a public meeting to discuss the results
of these studies, and a responsiveness summary for
the meetings shall be prepared.
4. Before any EPA construction funds are awarded, Metro
shall have an approved sludge disposal plan.
5. Metro shall establish a formal procedure to ensure
that, prior to any new interceptor extension or
connection to the Renton system, local land use
agencies shall evaluate, with public input, the
potential impacts of sewered development on environ-
mentally sensitive areas. Those include prime
agricultural lands, wetlands and floodplains. The
procedures shall stipulate that consideration be
given to alternatives that would avoid adverse
impacts and recommendations to mitigate adverse
impacts.
6. Should connections which transfer wasteloads from
the West Point system to the Renton system be found
cost-effective in final West Point facilities plan-
ning, Metro shall ensure that construction of the
selected tunnel and outfall from the Renton treat-
ment plant will be completed prior to completing
construction of any such West Point system connection.
7. Before construction, Metro shall prepare a plan,
in coordination with EPA and DOE, which sets out
the measures that will be taken to minimize adverse
impacts to Seahurst Park from construction of the
tunnel and outfall if Seahurst is the selected outfall
location. The plan shall also include measures
that will be taken to complete restoration of the
park, after construction is completed. These
measures shall be incorporated into construction
contracts. The restoration plan shall include
an estimate of the time required to complete
restoration.
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8. Metro shall prepare a spoils disposal plan. The
plan shall include specific methods and locations
for handling and disposal of spoils from tunnel
construction, and shall present measures to mini-
mize adverse impacts from spoils storage and dis-
posal .
EPA additional recommendations are as follows:
1. EPA recommends that appropriate local agencies take
every available action to ensure that the facilities
plan recommendations for management of on-site waste-
water systems in the nonsewer area are implemented.
Of specific concern is the need to develop a manage-
ment system for subsurface system maintenance and
solids disposal in King County.
2. EPA encourages Metro to continue to investigate
and implement measures to minimize near-term water
quality problems in the Duwamish River during design
and construction of diversion facilities.
3. EPA recognizes the importance of the "Duwamish Pollutant
Inventory" study and recommends that Metro work
actively with appropriate agencies to ensure imple-
mentation of the recommendations of that study.
4. EPA recommends that PSCOG and Metro work closely
together to develop realistic 50-year waste load
forecasts for the purpose of sizing nonmodular
facilities.
5. The Washington State Department of Ecology has begun
a Puget Sound sensitive area study to identify and
prioritize sensitive areas, develop a monitoring
strategy, and develop DOE program direction, in
coordination with other agencies. EPA believes
this is an important first step toward gaining an
understanding of water quality trends in Puget
Sound. EPA encourages DOE to build on this plan
by implementing the chosen monitoring strategy,
so as to acquire information about long-term Puget
Sound water quality conditions, in relation to
wastewater discharges.
The Effect of Public Involvement
i
EPA and Metro received a great many public and agency
comments during and following the 60-day review period on
the Draft EIS and draft plan. These comments have had a
VI 1
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major effect on EPA and Metro decision-making. More attention
has been focused on how the plan for the Renton treatment
plant fits into the total Metro regional system, on the likely
construction impacts of proposed tunnels, on the potential
impacts of proposed outfalls on Puget Sound and adjacent
beaches, and on the role of residents of the East Passage
area in agency decision-making.
The final plan proposes to defer the decision on where
to treat wastewater flows from the north part of the service
area currently treated at West Point. That decision will
be made in the context of planning for the entire Metro system
once decisions are finalized concerning level of treatment
at the plants presently discharging to Puget Sound.
Additional information has been developed concerning
the construction impacts of the proposed tunnel/outfall.
This has led to EPA's development of several grant conditions
concerning public review of additional predesign studies,
and concerning preparation by Metro of a construction site
plan and spoils disposal plan.
EPA and Metro have both worked to acquire more informa-
tion about the proposed outfall's effects on Puget Sound
water quality. Studies were done using the Puget Sound model
at the University of Washington with simulated Alki and Seahurst
discharges, to better assess differences in circulation patterns,
A computer analysis of diffuser and effluent plume behavior
was completed to confirm the ability to achieve 100:1 initial
dilution. Information was gathered on all dischargers to
Puget Sound south of Alki Point to determine the relative
role of pollutant loading from a Renton discharge. Information
was gathered on seasonal water column density gradients near
Alki and Seahurst to determine frequency of effluent plume
surfacing. Puget Sound sedimentation patterns were investi-
gated to identify areas likely to accumulate settlable materials
from the diluted effluent. All of this additional informa-
tion, presented in Chapter 6 of the Final EIS, has played
a key role in the EPA decision process.
The concern by East Passage residents over their voice
in the decision has led to an intensification of the public
involvement process beyond that normally followed. The comment
period on the draft plan and Draft EIS was lengthened, addi-
tional meetings were scheduled with East Passage area community
groups after the close of the comment period, a full series
of meetings and hearings has been scheduled to receive comments
on the final plan and Final EIS, and grant conditions have
been developed to ensure a community voice in subsequent
predesign and design work. EPA feels that these measures
have ensured that the affected public has had a major voice
in this decision.
VI 1 1
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A full public review process has been scheduled for
the Final EIS and final Metro plan. Over 200 copies of the
Final EIS and about 3,000 copies of a summary of the EIS
are being distributed for citizen and agency review and comment,
Metro has scheduled a series of public informational
meetings on the final plan at the following dates and loca-
tions :
Thursday, August 20
Monday, August 24
- Bothell City Council Chambers
- Ober Activity Center, Vashon
Island
- Metro Fourth Floor Conference
Room, Seattle
- Highline High School Cafetorium
- Puget Sound Power and Light
Auditorium, Renton
Wednesday, September 2 - Alki Congregational Church
Tuesday, August 25
Wednesday, August 26
Thursday, August 27
EPA and Metro will hold joint public hearings on the
Final EIS and final plan at the following dates and locations:
Tuesday, September 8
Wednesday, September 9
Thursday, September 10 -
Puget Sound Power and Light
Auditorium, Bellevue
Alki Congregational Church
Highline High School Cafetorium
Individuals or groups that wish to comment in writing
on the Final EIS may forward written comments to:
U. S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Attention: Roger Mochnick M/S 443
Comments should be sent by the close of the 30-day comment
period on September 14. All verbal and written comments
will be considered by EPA in reaching its final decision
following the close of the comment period.
General Responses to Most Frequent
Comments on Draft EIS
Many written comments received on the Draft EIS raised
similar issues and concerns. EPA's general responses to
these comments are presented here. The comments are grouped
within the following categories: water quality issues, waste-
water management planning issues, sensitive areas issues,
construction impact and neighborhood issues, and cost issues.
IX
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.sponses to cost issues were prepared with substantial input
rom Metro. All written comment letters received by EPA
^re reproduced in Chapter 12, along with specific responses
to comments.
1. What impacts will an outfall off Three Tree Point
(Seahurst Park) or Alki Point have on water quality
and beneficial uses at nearby shoreline areas and
in the main body of Puget Sound?
Significant impacts are not expected at either location.
The achievable initial dilution of the effluent in the imme-
diate vicinity of the diffuser (100 parts seawater to 1 part
affluent) will be great enough to avoid any significant impact
:>n beneficial uses.
Even though adverse impacts are not expected, it is
nevertheless possible that underwater geoduck clam beds that
are of potential commercial harvest value could be decerti-
fied by the State Department of Social and Health Services
for commercial harvest. Such beds are found both near Alki
Point and Three Tree Point. The Department of Social and
Health Services can use decertification as an automatic pre-
cautionary measure even when quantifiable public health
impacts are not predicted.
Several commentors were concerned about beach wash up
of effluent. The "worst case" would be effluent diluted
at 100:1 coming into contact with the shoreline. Based on
experience at West Point, diluted effluent at concentrations
up to about 270:1 may infrequently occur at beaches near
the outfall. The oceanographical causes of these occurrences
are not completely understood, and it may be impossible to
design an outfall and diffuser to completely avoid them.
However, these concentrations are not high enough to harm
beneficial uses (swimming, shellfishing) at the beaches.
The greatest impact may be one of quality of life, i.e.,
knowledge that diluted effluent may infrequently wash up
on beaches.
After initial dilution, the effluent will disperse,
become further diluted, and be transported out of Puget Sound
by net circulation patterns. Puget Sound modeling studies
indicate that effluent discharged off Alki Point would flow
predominantly northward, and effluent discharged off Three
Tree Point would flow predominantly southward and clockwise
around Vashon Island. Diluted effluent would not be trapped
in Commencement Bay. Diluted effluent may "pool" somewhat
in the Seahursr Park area during neap tides for periods of
4-5 days before being flushed away during periods of spring
-------
tides. These differences in circulation between Three Tree
Point and Alki Point do not appear to be significant with
respect to impacts on water quality, fisheries, or other
beneficial uses because initial dilution in the immediate
vicinity of the diffuser would be adequate at both locations.
2. What are the long-term impacts of the Renton discharge
off Three Tree Point (Seahurst Park) on south Puget
Sound, in relation to the cumulative effects of
other discharges to the south sound and the toxic
substances recently found in Commencement Bay?
Long-term degradation of Puget Sound due to treated
sewage discharges has not been found thus far, and the EIS
has found no evidence for such general degradation in the
future. If any general changes are occurring, they are too
subtle to be detectable by existing monitoring and studies.
The toxic substances recently found in Commencement Bay by
National Atmospheric and Oceanographic Administration (NOAA)
research appear to be related to discharge of industrial
wastes, rather than discharge of treated municipal waste-
water. Several agencies, including EPA, are engaged in further
studies of Commencement Bay to learn more about pollutant
sources and fates.
The pollutant loading, in terms of biochemical oxygen
demand (BOD), of the Renton discharge would represent about
one-fourth of the total BOD from point sources (discrete
municipal and industrial sources) discharging to the south
portion of Puget Sound (from Alki Point south). If nonpoint
sources (urban runoff, rivers) were considered, the relative
contribution of Renton plant waste loads would be considerably
less than one-fourth.
Many commentors expressed concern over the cumulative
impacts of persistent toxic substances (heavy metals and
organics) from the Renton effluent. The Renton effluent,
being mainly household wastewater, is relatively low in these
substances compared to industrial discharges. The contri-
butions of copper, lead, and zinc from the Renton discharge
would be 1 percent or less of the total contributions from
all sources of each of these metals to the sound. The main
effects of metals will probably be a tendency toward higher
metals concentrations in sediments and shellfish and other
sedentary invertebrates in the immediate vicinity of the
diffuser. Based on experience at other Puget Sound discharges,
these impacts are not expected to be significant. Relatively
little is currently known about the concentrations and poten-
tial effects of toxic organic substances in Renton effluent
XI
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and other waste discharges in the sound. Metro is currently
conducting a 3-year study of toxicant sources, treatment
processes, and fates in the environment. This study will
provide a better understanding of sources and concentrations
of metals and toxic organics, and may help provide the in-
formation necessary to make informed decisions about any
toxic control methods that need to be implemented. However,
these studies are still unlikely to completely resolve uncer-
tainties regarding the significance of low levels of toxic
substances in the marine environment, regardless of the
selected outfall location.
3. Are existing water quality problems in the Green/
Duwamish River related to Renton effluent discharge?
How serious is the problem now and in the future?
If the Renton effluent were removed, would water
quality be adversely affected due to less flushing?
What would be the cumulative effects of effluent
removal, the planned Corps of Engineers dredging
project, planned increases in diversions by Tacoma,
and the planned Soil Conservation Service Eastside
Drainage Project?
Studies have shown that dissolved oxygen (DO) sags near
the water surface in the Duwamish estuary are partially caused
by ammonia in the Renton effluent. DO sags in the salt wedge
near the bottom have not been linked to the Renton effluent.
Surface DO is now at about the minimum level for maintenance
of healthy salmon and trout populations. Future decreases
in DO would impair the health of the fish populations if
Renton effluent continued to be discharged to the river without
nitrification. Ammonia levels would become lethal to salmon
and trout in a matter of hours during periods of high pH
due to algal blooms. Occasional fish kills could occur in
late summer or early fall.
Removal of Renton effluent from the river would essen-
tially eliminate the surface DO sags and the threat of ammonia
toxicity. The main potential downstream benefit of leaving
Renton effluent in the river would be to decrease the resi-
dence time of water in the estuary, thereby reducing the
amount of oxygen removed from that water by oxygen-demanding
pollutants in estuary bottom sediments. However, a report
prepared for the Army Corps of Engineers by Harper-Owes states
that during low flow periods, when this effect is of concern,
tidal exchange rather than freshwater inflow controls resi-
dence time. The report concluded that "flow enhancement
to 12.2 m3 per second will not significantly affected wedge
residence time or location". Flow enhancement to 12.2 m3
per second would correspond to leaving Renton effluent in
xn
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the river. Another potential benefit of higher freshwater
flows is to increase turbulence in the water column, which
may inhibit the development of algal blooms. On the other
hand, leaving the effluent in the river can result in high
levels of ammonia, which can become toxic due to the effects
of algal blooms. Even if ammonia were removed by nitrification,
the Renton discharge would increase river temperature, con-
tribute heavy metals, and could lead to problems of toxicity
from either chlorine or sulfur dioxide. In addition, leaving
the discharge in the river retains the risk of treatment
plant upset, and resulting impacts. On balance, the minor
and speculative benefits of leaving the effluent in the river
are clearly outweighed by the environmental damage that could
result.
Several commentors were interested in the relationship
between removal of Renton effluent and the planned Corps
of Engineers Duwamish River dredging project, planned in-
creases of water diversions by Tacoma, and the planned Soil
Conservation Service Eastside drainage project. The Corps
of Engineers studies have shown that the Corps dredging project
will not significantly affect DO. Increased Tacoma diver-
sions will not change late summer-early fall flows and hence
will not lower salt wedge DO during the season when the wedge
inherently has the lowest DO. Upgrading the Renton treatment
plant could relate to the upstream Green River flood control
planning through either effects of changes in river flow
levels from flood control or effects of increased urbani-
zation in the floodplain. Any change in river flow levels
resulting from raising levees would not affect flows during
the summer when flow effect on water quality and fisheries
is of most concern. The Corps has stated that it would not
be feasible to make operational or structural changes at
Howard Hansen Dam for purposes of flood control.
Increased urbanization in the floodplain is a potential
secondary impact of both increased sewage treatment capacity
and increased flood control, since absence of either acts
as a constraint on urbanization. Ultimately, control over
growth and mitigation of growth-related impacts is the res-
ponsibility of local government. Federal agencies whose
actions remove constraints to growth should work with local
agencies to encourage mitigation.
Wastewater Management Planning Issues
4. Should not a comprehensive wastewater management
plan for the East Passage and other south Puget
Sound dischargers be prepared?
Xlll
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Previous regional wastewater management planning for
southwest King County was done under Section 303(e) of the
Clean Water Act. Although those studies did not establish
the assimilative capacity of south Puget Sound or determine
maximum pollutant loadings, they did conclude that water quality
standards in the sound would be met if municipal wastewater
discharges received secondary treatment. Since the proposed
Renton discharge will receive secondary treatment, it is
considered consistent with previous regional planning.
Monitoring of long-term trends in Puget Sound is planned
by both Metro and DOE. DOE is responsible for issuing dis-
charge permits and setting effluent standards. If adverse
cumulative impacts were to become evident in the future,
DOE has the authority to impose additional discharge require-
ments on any dischargers in the area, including Metro.
5. Why is not sludge disposal a part of Metro's waste-
water management plan?
The handling and processing of Renton sludge is discussed
in Metro's Wastewater Management Plan, whereas the utilization/
disposal of the sludge is being planned in conjunction with
Metro's systemwide sludge management program. The sludge
handling and processing elements—thickening, digestion,
methane gas recovery and dewatering--are designed to yield
sludge which is suitable for land application, the preferred
method of utilization/disposal.
Metro's sludge management staff is currently preparing
a long-term sludge utilization/disposal plan which is scheduled
for completion in late 1982. The public will have an oppor-
tunity to participate in the preparation of the long-term
sludge utilization/disposal plan through a series of public
meetings and hearings. EPA will prepare an EIS on the sludge
plan which will meet the requirements of the state and
national environmental policy acts.
Sensitive Areas Issues
6. What impacts will population growth and the pro-
posed facilities have on wetlands., floodplains,
and agricultural lands? Are the proposed miti-
gation measures effective and consistent with
federal policies?
The secondary impacts of population growth accommodated
by increasing the capacity of Metro's wastewater facilities
have been described in Chapter 7 of the EIS. Using the PSCOG
population projections used for projecting flows to the Renton
V 1 V
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plant, Chapter 7 analyzes the impacts of population growth
on three important agricultural districts within the study
area, and finds that 21-27 percent of the prime farmland
within these districts could be urbanized by the year 2000.
Chapter 7 also compares the locations of high-growth sub-
drainage basins to the locations of soil-related sensitive
areas, wetlands, and floodplains, and concludes that high-
growth subdrainage basins containing large acreages of these
sensitive areas could be adversely affected by future growth.
Several commentors expressed concern regarding the con-
sistency of the EIS with EPA policies on agricultural lands,
wetlands, and floodplains. These policies, described in
Chapter 1 of the EIS, essentially require EPA to assess the
direct and secondary impacts of its grant decisions on agri-
cultural lands, floodplains, and wetlands, and to avoid or
minimize identified adverse impacts. This EIS complies with
these policies by analyzing in considerable detail (in Chapter 7)
the adverse secondary impacts of Metro's Wastewater Management
Plan, and by describing a number of mitigation measures.
Mitigation measures include continuation of existing local
plans and policies, or development of new procedures to in-
crease the level of protection. EPA has developed a grant
condition designed to ensure that impacts to agricultural
lands and sensitive areas are assessed, with public input,
prior to hookup of new interceptors to the Renton system.
Concerns regarding the construction impacts of specific
facilities in Metro's plan on agricultural lands, wetlands,
and floodplains were raised by the U. S. Fish and Wildlife
Service and Washington Department of Game. These agencies
cited sections of the Draft EIS stating that both the Redmond
connection and the North Creek/Hollywood connection would
pass through agricultural lands and sensitive areas, and
that the river crossing of one of the Alki Point tunnel/
outfall alignments would be near Kellogg Island, an important
wildlife habitat. New mitigation measures for construction
impacts of the Redmond connection, North Creek/Hollywood
connection, and Alki Point tunnel/outfall route do not appear
necessary as part of this EIS. The Metro recommended program
defers the decision on construction of the Redmond connection
or North Creek/Hollywood connection. Impacts of these facilities
may be avoided. If the decision is subsequently made to
construct the Redmond and North Creek/Hollywood connections,
Metro would seek an additional construction grant, and EPA
would develop appropriate mitigation measures as grant con-
ditions for site-specific sensitive areas impacts. Miti-
gation measures for impacts to Kellogg Island do not appear
to be necessary at this time, since the most likely Alki
route, Route D, would avoid Kellogg Island.
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Construction Impact and Neighborhood Issues
7. What are the seismic and geologic risks associated
with alternative routes to Puget Sound?
Soil, stability and seismic hazards are risks that would
be encountered with construction of a tunnel/outfall to Puget
Sound. In general, surface soil instability is associated
with two potentially hazardous conditions: erosion hazards,
and slide and slippage hazards. Construction in hazardous
areas could occur in the vicinity of the following three
areas: along the open-cut pipeline corridors, adjacent to
the tunnel portal areas and at the pump station site.
Based on King County's mapping of sensitive areas, the
proposed pipeline and tunnel alignments do not encounter
any designated erosion hazard areas. Slide and slippage
(landsliding) hazards, however, do occur along the proposed
alignments. King County designates potential landslide
hazards based primarily on slope inclination greater than
15 percent. In addition, the physical character of the sub-
surface material is considered.
The coastal shoreline in the Three Tree Point area has
been designated by King County as a moderate to serious land-
slide hazard area, and similar conditions are likely to exist
at Alki Point as well, based on slope considerations. There-
fore, the design and construction of facilities in the coastal
zone, such as the proposed pump station, will have to take
landslide hazards into account. Because tunnel portals and
the pipeline adjacent to the Duwamish River could also en-
counter landslide hazard areas, such facilities must be
designed and constructed with these factors in mind.
Regarding seismic risks, the entire Puget Sound basin
is classified by the U. S. Geological Survey as a Zone 3
seismic risk area indicating high seismic activity. This
classification is characterized by a history of major earth-
quake frequency and associated damage. Several earthquake
faults are known to exist within the Puget Sound area in-
cluding a recently discovered fault which runs through Alki
Point. This fault, however, is considered to have been in-
active during recent years.
A precise determination of geologic and seismic risks
cannot be made until predesign engineering and geotechnical
studies are completed by Metro. Facilities will be designed
to withstand frequent events and to fail safely in the extreme
but rare event. Metro's engineering consultant has experience
in designing tunnels in areas of even higher seismic risk
than Puget Sound. EPA has recommended analyses to be conducted
xvi
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in predesign studies to mitigate geologic and seismic risks,
and will include these recommendations in a grant condition
for funding the Metro plan. If the determination is made
in predesign studies that the recommended Seahurst Park route
is not feasible from the standpoints of cost, engineering,
or design, and Metro subsequently selects another route,
then a supplement to the Wastewater Management Plan and EIS
would be prepared and distributed for public review.
8. What are the impacts of the tunnel and outfall to
Puget Sound on neighborhood property values and
quality of life?
Properties adjacent to the tunnel portals and open-cut
areas would be subject to adverse construction-related impacts
such as noise, traffic disruption, increased truck traffic
and dust during the construction phase. These construction
conditions would last no longer than 27 months, and the physical
environment would eventually be restored. Marketing of pro-
perty during the construction phase could potentially be
more difficult, but this would be a short-term effect that
would end once construction is Completed.
Several individuals have asked whether the mere existence
of an outfall which discharges effluent might adversely affect
property values. In the absence of demonstrable on-shore
impacts of an outfall, it is highly unlikely that property
values would be affected. Data in the Final EIS indicate
that present beneficial uses of the shoreline and coastal
waters would not be affected by such occurrences.
Quality of Life is a subjective and elusive concept.
Other than short-term construction impacts, there is no
objective evidence in the EIS that present beneficial uses
of Puget Sound waters along beaches would be affected by
the discharge of Renton effluent to the sound. However,
the mere knowledge that diluted effluent may infrequently
wash up on beaches could, nevertheless, diminish perceptions
of the quality of the shoreline environment for some residents.
Cost Issues
9. Could cost sharing with other Metro facilities reduce
the cost of Alternative A-5?
Pages 50 and 51 of Metro's final plan contain a discussion
of the cost sharing potential with other Metro projects.
Figure 2-17 in the plan contains an estimate of the potential
savings associated with cost sharing with other pojects.
The conclusion reached is that the Seahurst Park outfall
xvn
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is still $32.2 million less expensive than an Alki Point
outfall even if all potential cost sharing projects are in-
corporated into a joint program. Of the $52.5 million
potential savings associated with the Alki tunnel, $38 million
is assigned to the Duwamish treatment plant outfall, $4.5
million is associated with the Alki treatment plant phase-
out, and $10.0 million is associated with CSO control pro-
jects. In order to "save" this raoney, Metro would have to
spend an additional $143 million. Even then it would be
less expensive to separately construct these projects with
a Renton effluent tunnel to Seahurst and a Duwamish effluent
tunnel to Alki.
10. How will rates for paying for the plan increase
over time?
Metro's projections for rate increases over time are
presented in Chapter 2 of the Final EIS. The rate increases
are a function of the Renton plant improvements, the amount
of state/federal grant funding available, and decisions to
be made concerning Metro's Puget Sound plants. If Metro
receives 33 percent of available statewide funding, and
implements a "full utilization" of West Point treatment"
plant's primary capacity, monthly rates would increase from
$4.50 in 1981 to $15.00 in 1990. The portion of this in-
crease attributable to improvements at the Renton plant alone
is about $6.00 per month in 1990.
11. How accurate are the draft plan cost estimates?
What is the probability of cost overruns for the
proposed tunnel?
Metro has indicated that the accuracy of the cost figures
contained in the draft plan is plus or minus 20 percent. The
cost estimate accuracy range has been "skewed" to -10 percent/
+30 percent by adding a 10 percent allowance. Included
in the cost estimates are a miscellaneous "contingency" allow-
ance of 5 percent, 20 percent for engineering services, and
5 percent for administration and finance costs. Thus a total
of 40 percent has been added to the actual construction
and operation and maintenance budget estimate.
Metro has indicated that the tunnel cost estimates are
also generally accurate to within ±20 percent, skewed for
a range of -10 percent/+30 percent. A similar 40 percent
is added to the actual construction and operation and main-
tenance budget estimate to account for construction contin-
gencies, engineering, contract administration and finance
costs. The actual tunnel construction costs are from cost
curves based on records maintained by Metropolitan Engineers
for Metro facilities, construction project reports containing
xvi 11
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cost data, and bidding prices and estimates from other West
Coast wastewater facilities. The cost curves are for soft
ground tunneling technique3 and include support plant and
equipment, excavation, dewatering, construction support system,
concrete lining, grouting, cleanup and contractor's overhead
and profit. The engineers' staff geologist has reviewed
surficial geological information and extrapolated it beneath
the ground. This revealed that the majority of the Alki
and Three Tree Point/Seahurst Park tunnels would be in gravel,
soft sandstone, shale and conglomerate. One hard rock section,
which has been identified near the eastern portal of the
Three Tree Point/Seahurst Park portal, would require a
different tunneling technique, but cost estimates would be
unaffected.
Actual tunnel costs could differ from the estimates
depending on geological conditions along specific routes,
the construction method, the1existence of mixed face condi-
tions, overlying shear zones, groundwater conditions, allow-
able length of construction period, the availability of portals
and access points, and precise tunnel alignments. More de-
tailed cost estimates1-will be prepared following geotechnical
investigations, including test borings and geophysical work
(seismic and downhole logging techniques).
12. What portion of the new facilities is required
to service future users? What proportion of costs
will be paid by new users? Is the proposed cost
allocation equitable?
The proposed project will serve existing and future domestic
commercial and industrial users. Metro has estimated that
100 percent of the expansion in treatment plant capacity
is attributable to growth; of these costs, 77 percent are
attributable to new domestic/commercial users and 23 percent
to new industrial users. About 74 percent of the solids
handling facilities capital costs are attributable to existing
users, with the remaining 26 percent attributable to new
users (13.5 percent domestic/commercial, 12.5 percent industrial)
For the tunnel/outfall, Metro estimates that 62 percent of
the costs are attributable to existing users, with the re-
maining 38 percent attributable to new users (36 percent
domestic/commercial, 2 percent industrial).
Overall, Metro estimates that about 56 percent of the
recommended program capital costs are for existing users
and 44 percent for future users. For operation and main-
tenance costs, both existing and new users will be paying
identical monthly fees, a portion of which will be used for
operating and maintaining the new facilities. Metro has
high strength and high volume surcharges on industrial users
to help ensure the industrial users pay their proportionate
share of costs.
XIX
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Metro staff believes that the existing rate system is
generally fair and equitable. Whether the rate structure
should be re-evaluated is a major policy issue which is being
considered by the Metro Council as they review the waste-
water management plan. The existing rate system requires
that all Metro rate extensions of interceptor sewers to the
core system be paid for by the new customers being served.
Each household connected to the sewer system pays Metro $4.50
per month. Of the $4.50 that comes to Metro, a portion is
used to pay for operation and maintenance of existing facili-
ties. The remainder of the monthly fee is used to pay off
the revenue bonds which were sold to finance the construction
of the Metro system.
EPA Decision-Making Issues
13. How does the EPA decision-making process work?
What is EPA's relationship with Metro?
Under Section 201 of the federal Clean Water Act and
its implementing regulations, Metro, as an applicant for
grant funding, prepares a facilities plan and submits it
to the state and EPA for approval. EPA offers federal grants
for the planning (Step 1), design (Step 2), and construction
(Step 3) of publicly-owned treatment works. Federal funding
for design and construction is dependent on EPA approval
of the facilities plan. Previously, Metro applied for and
received EPA funding to prepare the facilities plan. When
complete, the plan will be approved by the Metro Council,
certified by the state, and submitted to EPA.
EPA bases its decision whether to approve the facilities
plan for funding on Metro's satisfaction of requirements
for a complete facilities plan (40 CFR Part 35.917-1) and
requirements for a complete grant application (40 CFR Part
35.920-3). In addition, EPA approval is based on the water
quality-related need for the project, cost-effectiveness
of the applicant's preferred alternative, its environmental
soundness, its reasonableness and feasibility, the applicant's
ability to implement the plan, adequate public participation,
and state certification of the preferred plan.
To determine environmental soundness in a plan for major
facilities, EPA may independently prepare an EIS under the
National Environmental Policy Act, as part of its decision
to approve a plan. The EIS helps EPA analyze the impacts
of alternatives, including that preferred by the grantee,
and other alternatives developed by EPA as necessary. The
EIS is prepared by EPA, with its own technical consultant,
rather than by the; grantee, to allow EPA to take an objective
xx
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look at the environmental impacts. EPA reviews all pertinent
information, including information available from the grantee.
Note that this procedure differs from that under Washington
State's Environmental Policy Act (SEPA), in which a private
party often prepares an EIS on a proposed development, for
approval by a state permitting agency. Under EPA's procedure,
there is no separate "approval" of the EIS other than through
refinement of the EIS based on public review and comment.
Therefore, there is no conflict of interest in EPA both pre-
paring the EIS and using it to help make a decision whether
or not to approve Metro's facilities plan.
If EPA did not approve the facilities plan, Metro would
either modify the plan as necessary to gain EPA approval,
or seek funding elsewhere. The purpose of concurrent pre-
paration of the plan, by Metro, and the EIS, by EPA, is to
resolve any differing views on the best alternative in advance
of final agency decisions, so that unnecessary delays can
be avoided.
14. Why were East Passage residents not involved earlier
in the public participation program? Does tack
of sufficient public participation by these resi-
dents invalidate the Wastewater Management Plan
and EIS?
EPA believes that East Passage residents have had sub-
stantial opportunity to review the Draft Wastewater Manage-
ment Plan and EIS, and make known their questions and con-
cerns. A public meeting on the draft plan and EIS was held
in Burien on January 13, 1981 specifically to obtain input
for East Passage citizens. Over 175 citizens attended that
meeting. East Passage residents have also had the opportunity
to formally comment on the draft plan and EIS at public hearings,
and in writing to Metro and EPA; most of the citizen letters
EPA received on the Draft EIS were from East Passage residents.
In addition, Metro and EPA staff attended a number of community
group and .agency meetings in the East Passage area in February,
March, and April of 1981 to explain the draft plan and EIS
and to receive comments.
A number of comments received from East Passage residents
express disappointment that the residents were not consulted
earlier in the planning and environmental review process;
some residents stated they did not learn of the plan or EIS
until the time of the public meeting in January 1981. It
was not until relatively late in the planning process that
Three Tree Point/Seahurst Park was selected as a potential
xxi
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site for the Renton tunnel/outfall and EPA agrees that addi-
tional efforts should have been made to obtain earlier input
from East Passage residents. Nevertheless, EPA believes
that substantial input has been obtained from East Passage
residents to allow an informed decision, through the mechanisms
described above.
Participation by East Passage residents has made up
in sophistication and volume, for any deficiencies due to
lack of early notification by EPA or Metro. It is improbable
that additional time for comments by East Passage residents
could have improved on the substance of the comments that
were received, or brought additional information to light
which would affect decision making more than it has beei
affected already. Also, a full public review period has been
set up for the final plan and Final EIS to further enable
all interested citizens to express their views prior to final
decisions. This review will occur predominantly in the East
Passage area.
15. Is sufficient information available to select a
preferred tunnel/outfall location?
For any important decision it is best to have as much
information as possible. However, perfect knowledge is never
available, and is not really a prerequisite to a good decision.
What is required is enough information to clearly distinguish
among the available alternatives. Developing more information
prior to making a decision may be superfluous if it doe.1.;
not help in deciding among alternatives. Also, information
is expensive to acquire, both in time and money. It is better
to perform expensive detailed studies necessary to refine
the project design only on the selected alternative.
In this case, EPA feels that enough information is avail-
able to identify Seahurst Park as the cost effective and
environmentally acceptable outfall site. The key is to retain
the capability to reconsider the decision if unanticipated
information comes to light in the detailed studies, and to
monitor the operation of the outfall to gain more knowledge of
long-term effects. We believe we have these capabilities. EPA
review of the results of design studies is provided for by a
condition to the EPA grant, and Metro has committed to a
monitoring program.
Information resulting from detailed predesign studies,
such as geotechnical and oceanographic studies, will be care-
fully reviewed by Metro and EPA. If these studies were to
produce unanticipated information which could alter our pre-
ference for the selected alignment, the original tunnel/
outfall decision would be re-evaluated and other alignments
xxn
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considered. In that case, a supplemental EIS would be pre-
pared and circulated for public review and comment prior
to any change in the decision on tunnel/outfall location.
Public meetings also would be held. If the decision were
changed, new detailed studies would most likely be conducted
at the new location.
xxi 11
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SUMMARY
( ) Draft Environmental Impact Statement
(X) Final Environmental Impact Statement
Type of Action: Administrative
Purpose and Need for Action
The Municipality of Metropolitan Seattle (Metro) is
expected to apply to the U. S. Environmental Protection Agency
(EPA) for grant funds to design and construct improvements
to the Metro Renton treatment plant sewerage system. Metro
has prepared a Final Wastewater Management Plan for the 620-
square-mile Lake Washington/Green River Basins study area for
three major reasons: (1) the Renton treatment plant and
other facilities have reached their operating capacity and
need expansion to accommodate future growth; (2) increasing
quantities of secondary effluent from the Renton plant are
being discharged to the Green/Duwamish River, and near-term
ammonia, dissolved oxygen, temperature, and chlorine problems
can be forecast during low flow periods; and (3) much new
development within the study area will be using on-site
technologies, and these systems have the potential to adversely
affect water quality -
This EIS focuses on three major issues associated with
the Metro plan:
Costs: What are the comparative costs and financial effects
on users of the various near-term and long-term
alternatives considered by Metro?
Water What are the water quality and biological trade-
Quality: offs of continued discharge of Renton treatment
plant effluent to the Green/Duwamish River compared
to discharge to Puget Sound? What are the water
quality impacts, if any, of on-site systems in
the less developed portions of the study area?
Land What are the land use impacts of wastewater
Use: management alternatives for the study area, and
what impacts will growth accommodated by facilities
expansion have on water quality, agricultural lands,
sensitive areas, air quality, and public services
and finance?
XXV
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Description of Alternatives
Background
The Renton treatment plant has the capacity to treat
an average of 36 million gallons per day (MGD). The treat-
ment plant has been operating in a stressed mode for the past
2 years as wastewater flows have approached and exceeded the
36 MGD capacity; flows during the first quarter of 1980 were
above 40 MGD. The plant is generally meeting its discharge
limitations, however, because it was designed with several
back-up measures which provide reliability during higher
flows.
Flow projections for wastewater management planning
were based on the "policy" population projection prepared
by the Puget Sound Council of Governments (PSCOG). PSCOG
projects that the study area population will increase from
537,087 in 1980 to 805,000 in the year 2000, of which 631,000
will be sewered. Allowing for domestic flow, industrial
flow,- and infiltration and inflow, Metro projects a year
2000 average wet weather flow of 101 MGD. This projection
includes flows from the north part of the study area, which
is currently served by Metro's West Point plant.
The proposed sewer service area for Metro's plan consists
of those lands which are presenuly authorized to receive
sewer service by local land use plans or policies. The
remainder of the study area (the nonsewer area) consists of
lands for which long-term land use is certain (where local
policies indicate sewer service should not be provided) ,,
and lands for which long-term l.md use, and thus long-t^:rm
sewer service, is uncertain (lands where there is no cl jar
local policy guidance). The proposed service area map LS
consistent with local land use plans and policies, according
to an analysis done as part of this EIS.
Long-Term Wastewater Management Alternatives
Metro initially developed 15 long-term alternatives,
which are variations on three basic concepts: expansion
of the Renton treatment plant to process all wastewatei
generated in the sewer service area (example Program A),
expansion of the Renton plant and construction of a new plant
in the Kenmore area (example Program B), and construction
of six satellite plants in addition to the Renton expansion
and Kenmore plant (example Program C). Variations on these
concepts relate to level of treatment at the Renton plant
(secondary vs. nitrification vs. advanced waste treatment)
and to receiving water for Renton effluent (Green/Duwamish
River vs. Puget Sound).
XXVI
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Four final alternatives were selected by Metro for further
consideration following a screening process. These alternatives
are Alternative A-l (centralized processing at Renton plant
with nitrification and continued discharge to the Green/Duwamish
River) , Alternative A-3 '(centralized processing at the Renton
plant with discharge of secondary effluent to Puget Sound'off
the Point Pulley area), Alternative A-5 (same as A-3, but dis-
charge off Alki Point), and Alternative B-l (similar to A-l,
but with construction of a new secondary treatment plant in the
Kenmore area to treat sewage from the north part of the study
area).
Following further evaluation, Metro staff selected
Alternative A-3 or A-5 as the preferred long-term wastewater
management program (these alternatives differ only in the
Puget Sound outfall location) in its Draft Wastewater Manage-
ment Plan. Components of the preferred program included:
collection system changes (construction of the Redmond con-
nection and North Creek/Hollywood connection to convey waste-
water from the north part of the study area to the Renton
plant); expansion of the Renton treatment plant to 99 MGD;
construction of a tunnel and outfall to convey effluent to
Puget Sound at either Three Tree Point or Alki Point; and
installation of solids processing facilities at the Renton
plant (Renton sludge is currently discharged via a force
main to Metro's West Point plant).
In its Final Wastewater Management Plan, Metro has
recommended a selected tunnel and outfall route to Puget
Sound; the selected route would discharge treated effluent
via a 3,000-foot outfall off Seahurst Park. The final plan
recommended program calls for expansion of the Renton treat-
ment plant to only 72 MGD (versus the 99 MGD recommended
in the draft plan). The reduction in capacity reflects Metro's
deferred decision on whether to continue to serve sewered
areas currently tributary to the West Point treatment plant
at that plant, to divert these flows to the Renton plant,
or to construct a new Kenmore plant. If the West Point ser-
vice area flows were not transferred to the Renton plant,
collection system changes (Redmond and North Creek/Hollywood
connections) originally proposed in the draft plant would
be avoided.
This EIS emphasizes the environmental impacts that would
occur if Alternatives A-3/A-5 were implemented, primarily
because Alternative A-3 is a possible consequence of imple-
menting Metro's final plan recommended program, one which
would result if future planning decisions call for diversion
of West Point plant service area flows to the Renton plant.
In addition to evaluating the impacts of Alternatives A-3/A-5,
the EIS also describes the environmental impacts of the remaining
final alternatives considered in Metro's draft plan (Alter-
natives A-l and B-l) and the no-project alternative.
XXVI 1
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Other Aspects of the Final Wastewater Management Plan
Near-Term Collection System Projects. Two groups of
near-term collection system projects are identified in the
Metro plan: projects to be initiated and projects in progress.
These projects are not assessed here since they do not involve
decisions which currently must be made by EPA. Metro will
evaluate environmental impacts of these projects with the
State Environmental Policy Act.
Nonsewer Area. The Wastewater Management Plan recommends
management options for on-site systems in the nonsewer area
(the area for which sewers are not being planned over the
next 20 years). These recommendations include: establishing
a comprehensive program for design, construction, and main-
tenance of on-site and community systems; providing adequate
staffing, funding, and enforcement of on-site wastewater
management programs; encouraging experimentation with alter-
native technologies; and establishing a public education
program. These recommendations are incorporated within the
mitigation measures identified in this EIS for reducing
adverse secondary groundwater and surface water impacts caused
by continued growth in the nonsewer area.
Triggering Mechanism. The Wastewater Management Plan
proposes a monitoring program, termed the triggering mechanism,
to provide advance notice for expansion or additions to the
Metro sewerage system, to monitor performance of on-site
systems in nonsewer areas, and to monitor Puget Sound water
quality near the proposed outfall. This mechanism is not
separately analyzed in the EIS because it is itself a miti-
gation measure, and its impacts will be beneficial.
Sludge Disposal. The Metro plan assumes that long-
term disposal for Renton sludge will be accomplished by
application to forestlands, reclamation of marginal soils,
and composting. This proposal and other long-term sludge
disposal alternatives are currently being examined by Metro
in a separate planning effort, which will be accompanied
by a separate environmental review process.
Alternatives Available to EPA
EPA may develop other structural (facilities) alternatives
or administrative alternatives as part of its EISs on waste-
water facilities plans. In the case of the Metro Wastewater
Management Plan, EPA has determined that Metro has examined
a full range of structural alternatives, and that new structural
alternatives are not warranted as part of this EIS. EPA
administrative alternatives are of two types: funding and
grant conditions. EPA may decide to fund or not fund the
selected program, to fund one or both of the project phases,
and to fund or not fund capacity of facilities beyond the
xxvi i i
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20-year capacity. EPA may also place conditions on sub-
sequent design and construction grants to mitigate adverse
construction, operational, or secondary impacts. Grant
conditions being considered by EPA are discussed in the
FOREWORD to the EIS.
Assessment of Impacts
Impacts of Final Plan Recommended Program and Mitigation
Measures
Table S-l summarizes the cost, construction and site-
related, operational, and secondary impacts of the recommended
program, and describes possible mitigation measures. As
shown, the present worth costs of the recommended program
are $225 million. This does not include costs for transporting
and treating flows from the north part of the study area;
these costs would include either costs for the Redmond and
North Creek/Hollywood connections, or costs for certain modi-
fications to the West Point collection system.
By 1990, the recommended program would increase Metro's
monthly rates by about $6.00 per month, assuming Metro receives
33 percent of statewide grant funds. The total Metro 1990
monthly rate could vary between $15.00 and $35.00, depending
on which improvements are made at Metro's Puget Sound plants.
The recommended program would generate a number of con-
struction and site-related impacts. As shown in Table S-l, most
of these are attributable to the tunnel/outfall to Seahurst
Park. Adverse impacts include impacts caused by potential geo-
logic and seismic hazards, spoils tran'sport and disposal impacts,
disruption of recreational uses of Seahurst Park, and traffic
disruption. Most of these adverse impacts are short-term
in nature, and mitigation measures are available to reduce
their severity.
The main operational impacts of concern are water quality
impacts. Over the short-term, during the 5 years it takes
to design and build the recommended plan, deterioration in
Green/Duwamish River water quality can be expected as sewage
flows continue to increase beyond the Renton treatment plant's
treatment capacity- Temperature, dissolved oxygen, and ammonia
water quality standards would be violated, and DOE effluent
dilution guidelines (20:1) would continue to be exceeded.
Deteriorating water quality would increase the risks of im-
paired salmonid migration or fish kills. Mitigation measures
proposed by Metro to reduce these short-term impacts on the
Green/Duwamish River are listed in Table S-l, and additional
available mitigation measures are listed as well.
xxix
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Table S-l. Summary of Major Impacts and Mitigation Measures
for Final Plan Recommended Program
Impact
Mitigation Measures
I. COSTS
Present Worth Costs: $225,400,000
Estimated 1990 Metro Monthly Rate: Assuming Metro receives
33 percent of statewide grant funds, S15.00 with "full
utilization" of West Point plant, $35.00 with full secondary
treatment at Puget Sound plants. About $6.00 month attri-
buuable to Renton recommended program.
Unneeded.
Unneeded.
II. CONSTRUCTION AND SITE-RELATED IMPACTS
Construction and Site-Related Impacts
• Geologic and Seismic Hazards: Soil stability and seismic
hazards could be encountered along tunnel/outfall route.
• Spoils Transport and Disposal Impacts: Traffic and poten-
tial water quality impacts.
• Cultural Resources: Archeological remains could be encoun-
tered along tunnel/outfall route.
• Recrej tion: Disruption of recreational uses of Seahurst
Park .
• Trj flic: Increased truck traffic at Renton plant and tun-
nel portals durinq construction.
• Water QiicUjU.y: Potential rerouting of Seahurst Park Creek
ilurjim cons I rue t ion .
1. Metro-proposed detailed engineering and geotechnical stud-
ies should include:
a. Identification of areas of soil instability along route
and siting of facilities or development of construction
methods to reduce soil instability hazards.
b. Assessment of seismic hazards based on borings and site-
specific seismic investigations, and development of
project design to reduce seismic risks to acceptable
levels.
c. Re-assessment of Seahurst Park route based on engi-
neering and geologic studies from the standpoints of
cost, engineering and risk.
2. If Seahurst Park route not feasible, and another route
selected, supplements to Final Wastewater Management Plan
and EIS should be prepared.
1. Preparation of a final spoils disposal plan.
2. Compliance with DOE limits for sediment discharge if wet
transport is used.
1. Conduct detailed archeological survey of tunnel/outfall
route prior to construction.
1. Scheduling construction activities during off-peak re-
creation periods to the extent practicable.
2. Preparation of plan to establish detailed procedures to
reduce impacts and restore damaged areas.
1. Rerouting traffic around construction sites and providing
flagmen to ensure traffic safety.
1. Siting of outfall to avoid necessity for rerouting of
creek. If creek must be rerouted, rerouting should occur
during summer months, when impacts on aquatic life would
be least.
• Aesthetics. Pump station at Seahurst Park would be incom-
patible with natural park setting.
1. Selection of building design and materials to minimize
visual impacts.
-------
Table S-l. (cont'd.
Impact
Mitigation Measures
Construction Employment: 3,384 job-years.
Unneeded.
III. OPERATIONAL IMPACTS
x
x
Hater Quality and Aquatic Biology
• Short-Term Impacts on Green/Duwamish River: Temperature,
dissolved oxygen, and ammonia water quality standards would
continue to be exceeded. DOE effluent dilution guidelines
(20:1) would continue to be exceeded. Increased risks of
impaired salmonid migration or fish kills would result.
• Long-Term Impacts on Green/Duwamish River: Future water
quality problems in river avoided through diversion of efflu-
ent. Salt wedge of estuary could move further upstream if
DOE minimum flows not met. Dissolved oxygen in salt wedge
may decrease, but dissolved oxygen at surface would in-
crease. Future risks to aquatic life would be avoided by
diversion of effluent.
• Impact on Puget Sound from West Point Discharge: Improved
effluent quality due to Renton sludge removal, creating less
risk for aquatic life.
• Impact on Puget Sound from Renton Discharge: No signifi-
cant impacts likely. Localized increases in turbidity,
ammonia, and heavy metals near outfall. Possible heavy
metjl accumulation in mussels and clams near outfall. Cumu-
lative water quality and biological impacts not easily pre-
dictable due to insufficient information.
Resource Uses: Project would consume 53 million Kwh per
ycar~,S~5~u tons per year chlorine and 575 tons per year ferric
chlorido.
Measures to be Implemented:
1. Fast-track implementation of plant expansion.
2. Diversion of flow via sludge force mains.
3. Reduced summer flushing.
4. Industrial source control
Additional Measures Available
1. Interim nitrification with existing facilities.
2. Construct special nitrification facilities.
a. Ammonia stripping.
b. Roughing filters.
c. Breakpoint chlorination.
3. Use of Kent/Auburn lagoons.
4. Diversion of flow via Riverton/Renton pump station.
5. Diversion of effluent for land disposal.
6. Local agency infiltration control.
7. Water conservation.
8. Interim river flow augmentation.
9. Fisheries resource protection.
10. Sewer moratorium.
11. Eliminate septage disposal.
Unneeded.
Unneeded.
1. For heavy metals, complete Metro toxicant study and imple-
ment recommendations.
2. Metro-proposed detailed oceanographic and biological stu-
dies of outfall. Studies should include winter shoreward
current velocities near Seahurst Park and baseline moni-
toring of shellfish.
3. Monitoring of Puget Sound by Metro and DOE.
4. Improve chlorination system of Renton plant (improvements
currently underway).
Unneeded.
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Table S-l. (cont'd.)
Impact
Mitigation Measures
Growth-Related Impacts of Project Phasing: Requires Renton
tunnel/outfal 1 , which is nonmodular (cannot easily be ex-
panded in modules). Sized for 50-year population projec-
tions not based on PSCOG projections or local land use
po 1 i c i u s .
Recreation : Potential for additional recreation opportunities
incorporating planning facilities.
1. Reduce staging period.
2. Base 50-year flow projections on land use plans or PSCOG
population projections.
Unneeded.
IV. SECONDARY IMPACTS OF GROWTH PROJECTED FOR STUDY AREA
Air Quality : Population projections used for wastewater
management planning consistent with those used for Puget
Sound Air Quality Management Plan (AQMP). Therefore, in-
creased emissions from study area growth have been accounted
for in AQMP.
Surface Water and Aquatic Biology: Water quality deteriora-
tion and anadromous fish losses are occurring now because of
urbanization, and could continue in the future. High-growth
subdrainage basins will be particularly affected.
Gioundwater: Risks to groundwater (and surface water) from
inadequately sited, operated, or maintained on-site systems
in nonsewer area.
Land Use: Proposed service area is consistent with local
land use policies.
Prime Farmland Conversion: Between 3,950 and 5,213 acres of
prime farmland could be converted to urban uses over the next
20 years in the Sammamish Valley, Lower Green River Valley,
and Upper Green River Valley agricultural districts. This
represents 21-27 percent of the remaining prime farmland in
these three districts.
SeiuiLive Areas. Study area growth could occur on soil-
related sensitive areas, wetlands, and floodplains. High-
iii'ciwlli :>ul >il ra i naije basins which contain relatively lorqc
acreages
uf !".-c t "J
of these sensitive areas would be particularly
1. AQMP air quality control measures.
1. Metro 208 areawide water quality planning.
2. Local nonpoint source control programs.
1. Establish comprehensive on-site system management program.
2. Provide adequate staffing, funding, and enforcement.
3. Encourge experimentation with alternative technologies.
4. Establish public education program.
5. Determine groundwater carrying capacity.
6. Establish institutional agreements for on-site system
management.
Unneeded.
1. King County Purchase of Development Rights (PDR) program.
2. King County Sewerage General Plan (SGP) policies.
3. Metro Resolution 3380 policies.
4. King County modification of SGP and Metro modification of
Resolution 3380 to include additional King County prime
farmlands.
5. City development of prime farmland protection policies for
incorporated areas.
6. Conduct detailed prime farmland assessments for future-
interceptor sewers.
7. i;;,,.", Cr,i;r, i_y ordinance and Genera 1_ De_vcl gp_ment Guide
policies.
1. Local floodplain management programs and federal Flood
Insurance Program.
2. Conduct detailed sensitive area assessments for future
interceptor sewers.
-------
Table S-l. (cont'd.i
Impact
Mitigation Measures
Public Service Systems: Study area growth will increase
demands on public services such as wastewater management,
water supply, drainage, solid waste management, recreation,
social services, transportation, and electricity and gas.
Public Finance; Study area growth will increase both public
costs and revenues, and could create fiscal problems for
some local governments.
1. Implementation of existing comprehensive and special
purpose plans and policies of local agencies.
1. Implementation of existing local measures for financing
the costs of growth.
x
x
X
-------
Over the long-terra, water quality of the Green/Duwamish
River would be protected by diversion of Renton effluent
to Puget Sound. No major water quality or biological impacts
of discharge of Renton effluent to the sound off Seahurst
Park are expected. Minor impacts include potential localized
increases of certain pollutants in the immediate vicinity
of the outfall, and potential heavy metals accumulation in
shellfish in the immediate vicinity of the outfall.
Although no major water quality or biological impacts
are predicted with the Seahurst Park discharge, little in-
formation is available regarding cumulative impacts of all
waste discharges to Puget Sound, considering the proposed
Renton discharge together with other waste sources. However,
it should be recognized that much of the Renton treatment,
plant currently reaches Puget Sound indirectly via the Green/
Duwamish River; the Seahurst Par]- discharge should therefore
not be considered a ''new" point source in terms of overall Puget
Sound water quality.
The secondary impacts of growth projected for the study
area are an indirect consequence of implementing the recom-
mended program. Neither EPA nor Metro is institutionally
"responsible" for growth and secondary impacts. Because
the planned wastewater facilities will assist in accommodating
projected growth, the philosophy that EISs are full dis-
closure documents dictates that secondary impacts be exa-
mined in this EIS and mitigated where possible. As shown
in Table S-l, projected growth in the study area will have
a number of impacts on air and water quality, land use, atnd
public services and finance; mitigation measures for these
impacts are also shown in Table S-l.
Of particular concern to EPA are: (1) water quality
deterioration and anadromous fish losses caused by urbanization-
induced nonpoint source pollution; (2) risks to groundwater
from inadequately sized, operated or maintained on-site systems;
(3) conversion of prime farmlands (between 3,950 and 5,23.3 acres
of prime farmland could be converted over the next 20 ye£irs in
the Sammamish Valley, Lower Green River Valley, and Upper Green
River Valley); and (4) development on wetlands and floodplains.
EPA programs and policies require that these impacts be miti-
gated where possible. Mitigation measures listed in Table S-l
are not necessarily the responsibility of EPA or Metro, but are
nevertheless presented for public review.
Comparison of Alternatives
Table S-2 compares the costs, construction and site-
related impacts, operational impacts, and secondary (growth-
related) impacts of the recommended program, Alternatives
A-3/A-5, Alternative A-l, Alternative B-l, and the no-project
XXX IV
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Table S-2. Summary Comparison of Major Environmental Impacts: Wastewater
Management Alternatives for the Luke Wash ington/Green River Basins
Type of Impact
Impacts of Final Plan
Recommended Program
Impact of Alternatives
A-3/A-5
Impact of Alternative
A-l
Impact of Alternative
B-l
Impacts of No Project
I. COSTS
Present worth costs
Estimated 1990 Metro
monthly rate, assum-
ing Metro receives
33% of statewide
grant funds.
II. CONSTRUCTION
AND SITE-RFTATED
IMPACTS
Construction and
site-related impacts.
Construction
employment
III. OPERATIONAL
IMPACTS
$225,400,000 (dees not
include facilities for
north study area)
$15.00 with "full
utilization" of West
Point. $35.00 with
full secondary treat-
ment at Puget Sound
plants. About $6.00/
month attributable
to Renton recom-
mended program.
Construction and site
impacts from Renton
treatment plant improve-
ments (expansion to 72
MGD) and tunnel/outfall.
Impacts of tunnel/out-
fall include geologic/
seismic hazards, spoils
transport/disposal im-
pacts, cultural re-
sources impacts, recre-
ation use disruption,
increased traffic,
possible rerouting of
Seahurst Park Creek,
and visual impacts of Sea-
hurst Park pump station.
3,384 job-years
$279,000,000 (A-3)
$345,000,000 (A-5)
$267,000,000
Higher rates than re- Higher rates than re-
commended program. Exact commended program.
estimates unavailable. Exact rates unavail-
able.
$329,000,000
Higher rates than re-
commended program.
Exact estimates unavail-
able.
Construction and site
impacts from Renton
treatment plant improve-
ments (expansion to
99 MGD), tunnel/outfall
(same impacts as recom-
mended program), and
Redmond and North Creek/
Hollywood connections.
6,290 job-years (A-3)
8,770 job-years (A-5)
Construction and site Construction and site
impacts from Renton impacts from Renton
treatment plant improve- treatment plant improve-
ments (expansion to ments (expansion to
99 MGD plus nitrification)72 MGD plus nitrification)
and Redmond and North and Kenmore treatment
Creek/Hollywood connec- plant and tunnel/outfall.
tions. Requires purchase Requires purchase of
of 19 additional acres 19 additional acres at
at Renton plant. Renton plant.
4,050 job-years
5,450 job-years
Water quality and
aquatic biology-
Green /Duwamish
Kivi-r
Short-term: Temperature,
dissolved oxygen, and
ammonia water quality
standards would continue
to be violated. DOE
effluent dilution guide-
lines (20:1) would
continue to be exceeded.
Increased risks of impaired
salmonid migration or fish
kills would result.
Short-term: Same as
recommended program.
Short-term: Same as
recommended program.
Short-term: Same as
recommended program.
Short-term: Same as
recommended program.
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Table S-2. (cont'd.)
Type of Impact
Inpacts of Final Plan
Recommended Program
Imoact of Alternatives
A-3/A-5
Impact of Alternative
A-l
Impact of Alternative
B-l
Inpacts of No Project
-Green/Duwamish River
-Puget Sound
x
X
X
Resource Use
-Unerijy Uso
Long-term: Future water
quality problems in
river avoided through
removal of effluent.
Salt wedge of estuary
could move further
upstream if DOE
minimum flows not
met. Dissolved
oxygen in salt wedge
may decrease slightly,
but dissolved oxygen
at surface would
increase. Future
risks to aquatic
life avoided by
diversion of ef-
fluent.
Vfest Point discharge:
Improved effluent
quality due to Renton
sludge removal,
creating less risk
for aquatic life.
Renton discharge: No
major impacts. Localized
increases in turbidity,
ammonia, and heavy
metals near outfall.
Possible heavy metals
accumulation in mussels
and clams near outfall.
Cumulative water quality
and biological impacts
not easily predictable
due to insufficient
information.
g-term: Same as
recamended program.
Long-term: Ammonia and
dissolved oxygen prob-
lems mitigated through
nitrification. Tem-
perature standards,
DOE effluent dilution
guidelines, and DOE
estimated limitations
for copper, mercury,
and zinc would continue
to be exceeded. In-
creased temperatures
could adversely affect
salmonid migration.
Long-term: Same as A-l,
except that lower flows
would cause problems
to be less severe and
cause less risk to
salmonid migration.
53,000,000 Kwh/yr
Vfest Point discharge:
Improved effluent
quality due to sludge
removal and flow
diversion, creating
less risk to aquatic
life.
Renton discharge: No
major impacts. Localized
increases in turbidity,
ammonia, and heavy
metals near outfall.
Effluent surfacing
would occur less often
at Three Tree Point (A-3)
compared to Alki Point
(A-5) . Effluent dis-
persion by tidal cur-
rents more rapid, and
effluent residence time in
Puget Sound is shorter,
at Alki Point.
Cumulative water quality
and biological impacts
not easily predictable due
to insufficient information
87,000,000 Kwh/yr (A-3)
89,000,000 Kwh/yr (A-5)
West Pojjnt discharge:
Same as Alternatives
A-3/A-5.
Renton discharge: Ren-
ton discharge to Green/
Duwamish River enters
Puget Sound. No major
impacts expected.
Cumulative water quality
and biological impacts
not easily predictable
due to insufficient
information.
West Point discharge:
Same as Alternatives
A-3/A-5.
Long-term: Major ad-
verse ammonia and dis-
solved oxygen problems,
in addition to problems
noted for A-l. Severe
risks of impaired sal-
monid migration or fish
kills created. Contin-
ued existence of fishery
would be threatened.
West Point discharge:
No change — continued
violation of NPDES per-
mit suspended solids
limit due to Renton
sludge.
98,000,000 Kwh/yr
Renton discharge:
Same as A-l.
Kenmore discharge:
No major impacts.
Localized increases in
turbidity, ammonia, and
heavy metals near out-
fall. Possible heavy
metal accumulation in
mussels and clams
near outfall.
Cumulative water quality
and biological impacts
not easily predictable
due to insufficient
information.
75,000,000 Kwh/yr •
Renton discharge; Poten-
tial adverse water qual-
ity and biological im-
pacts on Puget Sound.
Cumulative water quality
and biological impacts
not easily predictable
due to insufficient
information.
Minor increases over
present energy use.
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Table S-2. (cont'd.)
Type of Impact
Impacts of Final Plan
Recommended Program
Impact of Alternatives
A-3/A-5
Impact of Alternative
A-l
Impact of Alternative
B-l
Impacts of No Project
-Chemical use
Growth-related
impacts of project
staging
553 tons/yr chlorine
575 tons/yr ferric
chloride
Requires Renton tunnel/
outfall, which is non-
modular (cannot easily
be expanded in modules).
Sized for 50-ysar popu-
lation projections not
based on PSCOG pro-
jections or local
land use policies.
760 tons/yr chlorine
791 tons/yr ferric
chloride
Requires North Creek/
Hollywood connection,
Redmond connection, and
Renton tunnel/outfall,
which are nonmodular.
Latter two sized for
50-year projections.
760 tons/yr chlorine
240 tons/yr sulfur
dioxide
872 tons/yr ferric
chloride
Same as Alternatives
A-3/A-5, except Renton
tunnel/outfall not
required.
550 tons/yr chlorine
170 tons/yr sulfur
dioxide
771 tons/yr ferric
chloride
More flexible than
other alternatives.
Only nonmodular
facility is Kenmore
plant tunnel/outfall.
Minor increases over
present chemical use.
Not responsive to future
study area growth.
Recreation
x
x
X
Potential for additional
recreation opportunities
associated with planned
facilities.
Potential for additional
recreation opportunities
associated with planned
facilities.
Potential for additional
recreation opportunities
associated with planned
facilities.
Potential for additional
recreation opportunities
associated with planned
facilities.
No effect
IV. SECONDARY IMPACTS
OF GROWIH PROJECTED
FOR STUDY AREA
See Table S-l. Impacts are same as shown in Table S-l except for no action. For no action, lack of wastewater treatment
capacity could encourage more growth outside study area and encourage lower density development within study area. Otherwise,
secondary impacts similar to those described for other alternatives.
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alternative. The present worth costs of the recommended
program ($225 million) are lower than the other alternatives,
but these costs are not directly comparable because the re-
commended program would require a number of improvements
to the West Point collection system not included in the $225
million estimate. The costs of the remaining alternatives
are, however, directly comparable to each other; Alternative A-l
has the least present worth costs, followed by Alternatives A-3,
B-l, and A-5.
Key trade-offs among the alternatives, in addition to
cost, are described below.
Alternatives A-3/A-5. Alternative A-3 is one possible
consequence of implementing the final plan recommended program.
It would result if the West Point deemphasis policy is continued
and require construction of the Redmond and North Creek/
Hollywood connections to serve the north part of the stuiy
area. As with the recommended program, construction of bhe
Renton tunnel/outfall would have adverse short-term impacts,
and additional adverse impacts would result from construction
of the Redmond and North Creek/Hollywood connections. Future
water quality problems and risks to salmonid migration i/i
the Green/Duwamish River would be avoided. Discharge of
Renton effluent to Puget Sound is not expected to create
major water quality impacts at either Three Tree Point (Alter-
native A-3) or Alki Point (Alternative A-5). At Three Tree
Point, effluent surfacing is predicted to occur less often
than at Alki Point. However, at Alki Point, effluent dis-
persion would be more rapid and effluent residence time in
Puget Sound would be shorter. |
Alternative A-l. Under this alternative, construction
impacts of the Renton tunnel/outfall would be avoided, but
construction impacts of the Redmond and North Creek/Hollywood
connections would still occur. Current ammonia and dissolved
oxygen problems in the Green/Duwamish River would be mitigated
by nitrification, but temperature standards, DOE effluent
dilution guidelines, and DOE estimated limitations for certain
heavy metals would all be exceeded. Salmonid migration could
be affected, particularly by increased temperatures in the
river. This alternative would require more energy and
chemicals than either Alternatives A-3/A-5 or Alternative B-l.
Alternative B-l. Under this alternative, construction
of the Redmond connection, North Creek/Hollywood connection,
and Renton tunnel/outfall would not be necessary; construction
of the Kenmore treatment plant tunnel/outfall could have
adverse short-term construction impact. Water quality and
fisheries impacts in the Green/Duwamish River from discharge
of nitrified effluent would be similar, but less severe,
xxxvi 11
-------
than those of Alternative A-l, because 20-year flows would
be 72 MGD vs. 99 MGD for the preferred program. No major
water quality impacts are expected from discharge of secondary
effluent from the Kenmore plant to Puget Sound. This alter-
native is more flexible than either Alternatives A-3/A-5
or Alternative A-l because it requires construction of only
one nonmodular facility, the Kenmore tunnel/outfall.
No-Project Alternative. Under the no-project alter-
native, no capital improvements would be made to the Renton
sewerage system, and the costs of the other long-term alter-
natives would be avoided. Major ammonia and dissolved oxygen
problems would occur in the Green/Duwamish River with con-
tinued long-term discharge of secondary effluent; also, the
additional water quality problems mentioned under Alter-
native A-l would be intensified. The ammonia and dissolved
oxygen problems would cause severe risks of impaired salmonid
migration and fish kills; the continued existence of the
Green/Duwamish River fishery, which has an estimated value
of over $10 million dollars, would be threatened. The no-
project alternative would not be responsive to study area growth;
lack of sewerage capacity could encourage more growth outside
the study area and more low density development using on-
site systems within the area.
Impacts Common to All Alternatives. All alternatives
would result in short-term deterioration of the Green/Duwamish
River water quality, as described under the recommended program.
Also, all alternatives except the no-project alternative
would indirectly create the secondary impacts described under
the recommended program.
Public Involvement
Public participation for this EIS has been coordinated
and, where possible, integrated with the full-scale public
participation program undertaken by Metro in preparing
its Wastewater Management Plan. Key EIS public partici-
pation activities have included publication and distribution
of an EIS information brochure, conducting scoping meetings,
an EIS presentation to the Renton 201 Citizens Advisory
Committee, attendance and participation in Metro public
meetings on wastewater management alternatives and the pre-
liminary wastewater management plan, and conducting of five
public meetings and two public hearings on the Draft EIS
and Wastewater Management Plan.
The Draft EIS was forwarded to numerous federal, state
and local agencies, special interest groups, private citizens,
and public libraries to act as both an informational document
XXXIX
-------
and as an avenue to comment on the proposed wastewater project.
Also, a separate public summary of the EIS was mailed to
over 1,200 individuals. Numerous written comments on the
Draft EIS were received; these are presented in Chapter 12
of the Final EIS.
A full public review process has been scheduled for
the Final EIS and final Metro plan. Over 200 copies of the
Final EIS and about 3,000 copies of a summary of the EIS
are being distributed for citizen and agency review and comment,
Metro has scheduled a series of public informational
meetings on the final plan at the following dates and loca-
tions :
Thursday, August 20 - Bothell City Council Chambers
Monday August 24 - Ober Activity Center, Vashon Is Land
Tuesday, August 25 - Metro Fourth Floor Conference
Room, Seattle
Wednesday, August 26 - Highline High School Cafetorium
Thursday, August 27 - Puget Sound Power and Light
Auditorium, Renton
Wednesday, September 2 - Alki Congregational Church
EPA and Metro will hold joint public hearings on the
Final EIS and final plan at the following dates and locations:
Tuesday, September 8 - Puget Sound Power and Light
Auditorium, Bellevue
Wednesday, September 9 - Alki Congregational Church
Thursday, September 10 - Highline High Scool Cafetorium
Individuals or groups that wish to comment in writing
on the Final EIS may forward written comments to:
U. S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Attention: Roger Mochnick M/S 443
Comments should be sent by the close of the 30-day comment
period on September 14. All verbal and written comments
will be considered by EPA in reaching its final decision
following the close of the comment period.
xxxx
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Chapter 1
INTRODUCTION
The Municipality of Metropolitan Seattle (Metro) has
prepared a Final Wastewater Management Plan for the Lake
Washington/Green River Basins. The boundaries of the study
area for this plan are shown in Figure 1-1.
This Final Environmental Impact Statement (EIS) has
been prepared by the U. S. Environmental Protection Agency
(EPA). The applicable EPA decisions are to approve the Waste-
water Management Plan and to partially fund projects called
for in the plan.
Metro's Wastewater Management Plan
Metro has prepared the Final Wastewater Management Plan
for the Lake Washington/Green River Basins for three major
reasons (Metro, 1981) :
1. The Renton treatment plant and several other sewerage
facilities have reached their, operating capacity and need
expansion to accommodate future growth. Metro has selected
a 20-year planning horizon to examine future treatment capa-
city needs, consistent with federal funding requirements.
2. Increasing quantities of secondary effluent from the
Renton plant are being discharged to the Duwamish
River, and near-term water quality problems can be
forecast during low flow periods; constituents of
concern'include ammonia, chlorine, dissolved oxygen,
and temperature.
3. Much new development within the study area will be using
on-site or community wastewater management technologies,
and these systems have the potential to adversely affect
water quality.
Development of the Wastewater Management Plan
Wastewater management planning for the study area has
been influenced by several previous wastewater planning efforts.
The most important of these are Metro's Comprehensive Plan
(Metro, 1959); the RIBCO water quality management study (STR
Inc., 1974b); Metro's Areawide Water Quality Plan (208 Plan)
-------
FIGURE 1-1. STUDY AREA BOUNDARIES
-------
(Metro, 1978b); and Metro's wastewater facilities planning
for its Puget Sound plants. The latter planning effort has
influenced current planning for the Lake Washington/Green
River Basins through recommending de-emphasis of the West
Point treatment plant, thereby increasing the Renton treatment
plant service area, and installing sludge handling facilities
at the Renton plant. The West Point de-emphasis policy will
be reconsidered when a decision is made regarding Metro's
application for a waiver of secondary treatment requirements
at West Point.
The detailed process for preparing the Wastewater Manage-
ment Plan for the Lake Washington/Green River Basins is described
in Metro's plan, and will only be summarized here. Between
August 1979 and April 1980, Metro issued six technical memoranda
serving as background data for the draft plan. These technical
memoranda and their associated appendices are often used
as sources of information for this EIS. The memoranda cover
the following topics:
Memo #1: A description of existing wastewater facilities
in the study area (Metro, 1979d)
Memo #2: A description of the environmental characteristics
of the study area (Metro, 1979e).
Memo #3: An analysis of agency plans and policies affecting
the wastewater plan (Metro, 1980a).
Memo #4: A description of alternative wastewater techniques
(Metro, 1980b).
Memo #5: A discussion of facilities planning issues, objectives
and screening criteria (Metro, 1980c).
Memo #6: An analysis of future wastewater flows and loadings
(Metro, 1980d).
In early April, Metro issued its preliminary plan, which
identified near-term and long-term wastewater management
alternatives for the study area. Public meetings were held
on the preliminary plan in May 1980. Metro's Draft Wastewater
Management Plan was released in December 1980.
Public meetings and hearings were held on the draft
plan in January 1981. Following this public input, Metro
released the Final Wastewater Management Plan in July 1981.
EIS Context
Major Issues Addressed by EIS
Preparation of a comprehensive wastewater management
plan for the 620-square-mile study area raises a number of
important and interesting issues. Based on public input
and consultation with affected agencies, the following three
issue_groups have been determined to be of greatest importance
to this EIS, and consequently are emphasized.
-------
Costs: What are the comparative costs and financial
effects on users of the various near-term
and long-term alternatives considered by
Metro?
Water Quality: What are the water quality and biological
trade-offs of continued discharge of
Renton treatment plant effluent to the
Green-Duwamish River compared to discharge
to Puget Sound? What are the water quality
impacts, if any, of on-site systems in
the less developed portions of the study
area?
Land Use: What are the land use impacts of wastewater
management alternatives for the study area,
and what impacts will growth accommodated
by facilities expansion have on water quality,
agricultural lands, sensitive areas, air
quality, and public services and finance?
These three general issue groups have been recognized
in Metro's preliminary plan by Metro as central to facilities
planning decisions. The EIS, while emphasizing the above
three issue groups, also covers the entire range of biophysical
and socio-economic impacts related to Metro's near-term and
long-term alternatives.
National Environmental Policy Act of 1969 (NEPA) Requirements
Under NEPA, all federal agencies must build into their
decision-making processes mechanisms for consideration of
the environmental effects of proposed actions and mechanisms
for minimizing adverse effects of these actions. The EIS
required by Section 102(2)(c) is the action-forcing mechanism
of NEPA. EISs must include a detailed statement on the following:
1. The environmental impact of the proposed action.
2. Any adverse impacts which cannot be avoided should
the project be implemented.
3. Alternatives to the proposed action.
4. The relationship between local short-term uses of man's
environment and the maintenance and enhancement of long-
term productivity.
5. Any irreversible and irretrievable commitments of resources.
In 1978, the Council on Environmental Quality (CEQ)
issued regulations implementing NEPA. Significant require-
ments of these regulations include maximum opportunities
for public participation (including EIS scoping meetings);
-------
page limitations for EISs; and an easy to understand writing
style. Each federal agency is responsible for preparing
its own procedures for implementing NEPA, which are to be
consistent with the CEQ requirements. EPA issued its final
regulations on November 6, 1979 (Federal Register, Vol. 44,
No. 216, pg. 64174).
EIS Chronology
The EIS for Metro's Wastewater Management Plan was ini-
tiated in August 1979. On September 26, 1979 and October 17,
1979, EIS "scoping" meetings were held in conjunction with
Metro public information meetings, to obtain public input
on important issues for the EIS. On October 2, 1979, EPA
published in the Federal Register its Notice of Intent to
prepare an EIS on Metro's Wastewater Management Plan.
In January 1980, the EIS consultant prepared a dis-
cussion paper on environmental screening criteria for use
by Metro in screening preliminary wastewater management
alternatives. Based on Metro's preliminary planning, a
preliminary Draft EIS was prepared and the findings reviewed
with key agencies prior to publication of the Draft EIS in
December 1980. Public meetings and hearings were held on
the Draft EIS in January 1981. Following this public input,
the Final EIS was prepared.
Subsequent EIS Activities
Public meetings and hearings on the Final EIS and Final
Wastewater Management Plan are currently scheduled for August
and September 1981. A Metro decision on the final plan is
scheduled for October 1981. Subsequently, EPA and the Washington
Department of Ecology will take final action to approve or
partially/conditionally approve the final plan; these actions
are scheduled for November 1981, following which a Record
of Decision will be published. A Step 2 design grant would
then be made according to state funding priorities.
Public Participation
The public participation program for this EIS has been
coordinated and, where possible, integrated with Metro's
extensive public participation program for its Wastewater
Management Plan.
An initial informational brochure describing the EIS
process and key issues was prepared by EPA in September 1979
and widely distributed. EIS scoping meetings held in September
and October 1979 were a major opportunity for public input in
-------
determining issues to be emphasized in the EIS. Periodic
presentations were subsequently made to the Citizens Advisory
Commitee for Metro's Wastewater Management Plan to advise
the committee of EIS status and receive comments. A public
summary of this Draft EIS was prepared and distributed to
an extensive mailing list. Public meetings and hearings
on the Draft EIS were held in January 1981.
The Draft EIS comment period, the public meetings and
hearings held on the Draft EIS, and the public comments and
responses included in the Final EIS fulfill EPA's formal
public participation responsibilities under the National
Environmental Policy Act.
Institutional Considerations
This section summarizes laws, policies, and regulations
affecting the EIS and identifies the roles of key agencies
affected by the Wastewater Management Plan and EIS. A more
detailed institutional overview of the study area is presented
in Appendix A to the EIS.
Laws, Policies, and Agencies Affecting the EIS
Clean Water Act. The U. S. Environmental Protection
Agency (EPA) is charged with administering the Federal Water
Pollution Control Act, commonly referred to as the Clean
Water Act. Section 201 of the Clean Water Act establishes
a construction grants program for municipal wastewater faci-
lities , wherein federal grants are offered for the planning
(Step 1), design (Step 2), and construction (Step 3) of publicly-
owned treatment works. Section 208 of the act establishes
an areawide waste treatment management planning process.
Section 208 plans must develop controls for both point and
nonpoint sources of water pollution. Under Section 303 of
the act, states are required to prepare and enforce ambient
water quality standards and to prepare basin plans showing
how these standards will be met. Lastly, under Sections 401
and 402 of the act, EPA or the states are required to issue
National Pollutant Discharge Elimination System (NPDES) permits
for all point sources of pollution •
Within the Lake Washington/Green River Basins, the State
Department of Ecology (DOE) administers the construction grants
program and the NPDES program, and sets water quality standards.
In 1975, DOE prepared the 303(e) basin plan for the Cedar and
Green River basins. Metro's water quality planning responsi-
bilities in the study area include both areawide (208) and
wastewater facilities (201) planning.
-------
Section 404 of the Clean Water Act sets forth a regulatory
program for dredge and fill activities. Under this section,
the Corps of Engineers issues permits for the discharge of
dredged or fill materials into waters of the United States
and on adjacent wetlands.
Clean Air Act. Under the Clean Air Act, states are
required to prepare State Implementation Plans (SIPs)
demonstrating means for achieving and maintaining national
ambient air quality standards. The EPA procedures for
implementing NEPA require formal consultation with state
and regional air quality planning agencies to determine con-
formity of a proposed action with the SIP- The Draft EIS
must include a statement indicating whether the project con-
forms with the SIP- If the project does not conform to the
SIP, EPA will not give the project final approval. EPA has
determined that the proposed project does conform to local
portions of the SIP because both involve the same population
projections (see Chapter 7).
Endangered Species Act. Under this act, federal agencies
are prohibited from jeopardizing threatened or endangered
species or modifying habitats essential to their survival.
EPA procedures for implementing NEPA require formal con-
sultation with the Fish and Wildlife Service or National
Marine Fisheries Service, as appropriate, and subsequent
development of mitigation measures if endangered species
may be affected by a project. EPA has determined that the
proposed project will have no effect on any listed threatened
or endangered species (see Chapter 3).
Fish and Wildlife Coordination Act. Under this act,
federal agencies involved in projects resulting in modi-
fications of streams or other water bodies are required to
protect fish and wildlife resources which may be affected
by the project. EPA procedures for implementing NEPA require
consultation with the Fish and Wildlife Service and appropriate
state wildlife agencies to develop mitigation measures for
adverse impacts. Such consultation has occurred during preparation
of this EIS. The status of fish and wildlife resources in
the study area is discussed in Chapter 3 of the EIS.
EPA has received comments from these agencies on the
Draft EIS (see Chapter 12). EPA will include a grant condition
requiring Metro to mitigate potential impacts to geoduck
beds near the outfall site (see Chapter 8). Fish and wildlife
agencies will have another opportunity to suggest mitigation
measures during their review of Corps of Engineers permits,
which Metro will be required to obtain prior to any con-
struction in navigable waterways (see Chapter 5).
-------
National Historic Preservation Act. Under this law,
if federal agencies undertake activities affecting sites
of historic, architectural, archeological, or cultural value
that are listed on the National Register of Historic Places,
then the Advisory Council on Historic Preservation (ACHP)
must be consulted and mitigation measures must be developed.
EPA has consulted with the latest edition of the National
Register of Historic Places, which shows a number of listed
sites in the study area. However, no listed or eligible
sites are near the Renton treatment plant or the proposed
tunnel/outfall route. Therefore, EPA has determined that
no listed or eligible site will be affected by the proposed
action (see letter from Advisory Council on Historic Pre-
servation, and response, Chapter 12).
Archeological and Historic Preservation Act. This law
requires federal agencies to undertake data recovery and
preservation activities if federal activities may cause
irreparable destruction of significant scientific, pre-
historic, historic, or archeological data. In consultation
with the State Historic Preservation Officer (SHPO), and
based on a cultural resources survey at the Renton treatment
plant site, EPA has concluded that the expansion of facilities
at that site will not affect cultural resources. Cultural
resources along the proposed tunnel corridors have not been
inventoried. Prior to construction, Metro shall ensure that
a cultural resource survey is conducted, in consultation
with the SHPO, and that the requirements of the Archeological
and Historic Preservation Act are met (see Chapters 5, 8,
and comment letter from SHPO in Chapter 12).
Coastal Zone Management Act. This act establishes funding
and requirements for state coastal zone management programs;
in Washington, shoreline management programs have been prepared
to meet requirements of both the state Shoreline Management
Act and the federal act. Under the EPA procedures for imple-
menting NEPA, if EPA activities have significant coastal
zone impacts, then a determination of consistency with the
applicable coastal zone management program is required.
EPA, in consultation with the King County shoreline manage-
ment staff, has determined that the proposed tunnel and out-
fall would be consistent with the state coastal zone manage-
ment program for Seahurst Park. In consultation with the
City of Seattle shoreline management staff, EPA has determined
that there is some uncertainty regarding consistency of the
proposed tunnel and outfall with the state coastal zone manage-
ment program for Alki Point. Metro would be required to
obtain a shoreline permit from either King County or Seattle,
depending on the selected outfall location. For Alki Point,
Metro would be required to demonstrate that no feasible outfall
location exists in a less restrictive shoreline class (see
Chapter 5).
-------
EPA Policy on Agricultural Lands Protection. In September
1978, EPA issued its policy, pursuant to Executive Order 11988,
to' protect environmentally significant agricultural lands.
Under this policy, EPA is required to identify the direct
and indirect impacts of its actions on environmentally signi-
ficant agricultural lands, and to avoid or mitigate, to the
extent possible, identified adverse impacts. Potential adverse
impacts and corresponding mitigation measures have been identi-
fied in the EIS (see Chapter 7), and a grant condition will
be included to encourage implementation of mitigation measure:;
(see Chapter 8).
EPA Policy on Floodplain and Wetlands Protection. In
January 1979, EPA issued its statement of procedures on
floodplain management and wetlands protection, pursuant to
Executive Order 11990. Under these procedures, EPA is
required to assess floodplains and wetlands impacts of its
actions, and to either avoid adverse impacts or minimize
them if no practicable alternative to the action exists.
Potential adverse impacts and corresponding mitigation measures
have been identified in the EIS (see Chapter 7), and a grant
condition will be included to encourage implementation of
mitigation measures (see Chapter 8).
Affected Agencies and Their Jurisdictions
Environmental management within the study area is carried
out by a large number of federal, state and local agencies,
many of which will be affected by Metro's Wastewater Management
Plan. Table 1-1 is a matrix of agency responsibilities in
the Lake Washington/Green River Basins. For each agency,
responsibilities in each functional area are classified as
either advisory, planning, regulatory, implementing (con-
struction and operation), or funding. Not shown in this
table are the numerous agencies engaged in research and
monitoring activities. The responsibilities of key affected
agencies are summarized below.
Environmental ProtectionAgency. The EPA has regulatory
authority in the fields of water quality, wastewater manage-
ment, water supply, solid waste management, and air quality.
EPA water quality responsibilities are established in the
Clean Water Act, the provisions of which have been previously
reviewed. EPA responsibilities in water supply, solid waste,
and air quality are established in the Safe Drinking Water
Act, Resource Conservation and Recovery Act, and Clean Air
Act, respectively.
-------
Table 1-1. Institutional CX'ervisw:
Lake Washington/Green River Basins
Agency
Wa stewater
Management
Water
Supply
Public Service Systems
Drainage/
Flood Control
Solid Waste
Management
Environmental Management
Recreation Transportation
Water
Quality
Fish and
Wildlife
Air
Quality
Land Use
Federal
EPA
Army Corps of
Engineers
Depart, of Housing
& Urban Develop-
ment
USDA, Forest
Service
Heritage Con-
servation s
Hecreation
Service
Depart, of
Transportation
Fish & Wildlife
Service
State
Dept. of Ecology
Dept. of Fisheries
Dept. of Game
Dept. of Natural
Resources
Parks & Recreation
Ccrmussion
Dept. of Social &
Health Services
Dept. of Trans-
portation
Regional/Local
PSCOG
Seattle-King County
Dept. of Public
Health
Nfctro
Counties
R
PI$
$
PRI$
R
R$
R$
R
R$
PRIS
AS
PI$
R$
PR?
R
R
R
R
R
PR
RI$
PRI$
PI$
R$
R
R
R$
R$P
R$I
R$I
R$
PR
PIS
R
PIS
p
p
PRI$
R
PIS
PIS
PIS
PIS
R
PIS
PRIS
PRIS
-------
Table 1-1 (cent.)
Public Service Systems Environmental Management
WastewaterWaterDrainage/Solid WasteWater Fish and Air
Agency Management Supply Flood Control Management Recreation Transportation Quality Wildlife Quality land Use
King County
Soil Con-
servation District A A A
Cities PI$ PI$ PRI$ PI$ PI$ PI$ PRJ$ PRI$
Water and Sewer
Districts PI$ PI$ PJ$
Sno-met PI$ PI$ PI$
Puget Sound Air
Pollution Control
Agency PR
CODE
A = Advisory
P = Planning
R = Regulatory
I = Implementing
$ = Funding
-------
Corps of Engineers. Under the federal Flood Control
Act, the Corps of Engineers is responsible for flood control
planning and implementation on major rivers and streams.
Under Section 404 of the Federal Water Pollution Control
Act, as amended, the Corps administers the national permit
program for dredge and fill activities. Also, under Section 10
of the River and Harbor Act of 1899, the Corps issues permits
for the performance of any work in the navigable waters of
the United States.
Department of Ecology. The DOE is the equivalent of
EPA at the state level, having regulatory responsibility
in the fields of water quality, wastewater management, solid
waste management, air quality, and flood control. In addition,
DOE administers the state Shoreline Management Act.
Departments of Fisheries and Game. The Department CM:
Fisheries is responsible for managing food fish and shell
fish, whereas the Department of Game is responsible for
managing various game species, including game fish. Thes :
agencies advise DOE on water rights and allocation, and mist
jointly issue a hydraulics permit for alteration of natur .1
streams and their uses.
Department of Natural Resources. This department is
a natural resource agency within the state, with res-
ponsibility for state lands management, forest practices,
geological services, and limited drainage and flood control
activities.
Puget Sound Council of Governments. PSCOG is a voluntary
association of local governments within King, Kitsap, Pierce
and Snohomish Counties. PSCOG is responsible for developing
advisory regional plans and policies, and is also responsible
for conducting reviews of projects using federal assistance
under Office of Management and Budget Circular A-95.
Metro. Metro is a regional service agency with planning,
implementation, and funding responsibilities in the fields
of water quality and transit. Metro's past water quality
planning activities have included management of the River
Basin Coordinating Committee (RIBCO) studies, preparation
of the 208 areawide water quality management plan, and
preparation of a facilities plan for its four Puget Sound
plants. Metro acts as a "wholesaler" for wastewater services.
Counties and Cities. The Lake Washington/Green River
Basins contain portions of three counties (King, Snohomish,
and Pierce) and 18 cities. As general purpose governments,
these counties and cities undertake a spectrum of public
services and environmental management activities.
12
-------
Special Districts. Numerous special purpose districts
exist within the study area, providing key services such
as water, sewers, and schools.
Existing Sewerage Facilities
The Study Area
The study area encompasses 620 square miles north, east
and south of Lake Washington (see Figure 1-1). About 25
percent of this land presently has access to sanitary sewer
service; the balance of the area is rural and relies on septic
tanks for sewage disposal. The study area includes 40 local
sewering agencies (listed in Table 1-2 and mapped in Figure
1-2), 32 of which are sewered.
The Renton division of Metro operates the wastewater
collection and treatment system which collects wastewater
from most of the study area and transports it to the Renton
sewage treatment plant for treatment and disposal. The
West Point division of Metro currently operates this col-
lection system in the north part of the study area, where
the wastewater is transported to the West Point treatment
plant for treatment and disposal. Under the recommended
wastewater management program in Metro's final plan, sewered
areas tributary to the West Point plant would continue to
be served by that plant.
Study Area Wastewater Collection Systems
The Metro collection system in the study area consists
of approximately 116 miles of interceptors, trunks, force
mains, inverted siphons, and tunnels as well as 20 pumping
stations. Figure 1-3 shows the location of the Metro collec-
tion system, the existing service areas, and local service
areas designated by King County's Sewerage General Plan as
eligible for sewer service.
Where sewer lines cross waterways, flows typically are
carried underneath the water channel in an inverted siphon,
i.e., a pipe which is essentially always full of water and
is capable of sustaining some internal pressure without leaking
Similar pressure pipes are called force mains when the pressure
is produced by a pumping facility. The Renton division system
currently incorporates approximately 5 miles of siphons,
ranging from 8-54 inches in diameter, and a total of 10.1
miles of force mains, with diameters ranging from 12-20 inches.
13
-------
Table 1-2. Renton Study Area Local Sewerage Agencies
No. Agency
1 City of Everett
2 Fircrest Sewer District
3 Snohomish County
4 Silver Lake Water District
5 Alderwood Water District
6 City of Edmonds
7 City of Mountlake Terrace
8 City of Brier
9 City of Lynnwood -
10 Northeast Lake Washington
Sewer District
11 City of Bothell
12 King County Water
District No. 104
13 King County
14 Holiday Lake Sewer District
15 City of Kirkland
16 City of Redmond
17 City of Bellevue
18 Sahallee Sewer District
19 King County Water
District No. 82
20 King County Water ,
District No. 1211
21 Shorewood Apartments
22 East Mercer Island
Sewer District
23 Mercer Island Sewer District
24 King County Water
District No. 107
25 Eastgate Sewer District
26 Lake Sammamish State Park
27 City of Issaquah
28 Bryn Mawr Sewer District
29 City of Renton
30 King County Water
District No. 90
31 Val-Vue Sewer District
32 City of Tukwila
33 Cascade Sewer District
34 King County Water
District No. 108
35 City of Kent
36 City of Auburn
37 King County Water
District No. 86
38 City of Black Diamond
39 City of Algona
40 City of Pacific
Sewered Currently (1979) served byj_
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Everett
Everett
Metro (West Point)/Lynnwood
Edmonds
Lynnwood
Metro (West Point)
Lynnwood
Metro (West Point)
Metro (West Point)
Metro (West Point)
Metro (Renton)
Metro (Renton and West Point)
Metro (Renton and West Point)
Metro (West Point)
Metro (West Point)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton and West Point)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton)
Metro (Renton;
Metro (Renton]
1
Moraod with KCWD No. 82 in 1979.
SOURCE: Metro, 1979d.
14
-------
LEGEND-
SOURCE METRO, 1979*
FIGURE 1-2. COMPONENT AGENCIES IN THE RENTON STUDY AREA
-------
-LEGEND-
SOURCE: MODIFIED FROM METRO, 1979(1
FIGURE 1-3. LOCAL SERVICE AREAS, EXISTING SEWER SERVICE AREAS
6. METRO COLLECTION SYSTEM
-------
Almost all of the gravity lines are constructed of re-
inforced concrete pipe. The force mains and siphons are
usually steel, cast iron, or reinforced concrete pipe.
Most of the Renton area sewerage facilities were con-
structed in the past 20 years; however, some were obtained
by Metro from local agencies. With the exception of isolated
problems, the sewer system, which is under continued surveil-
lance, is basically in good repair and has rehabilitation
plans underway for all known areas of leakage or deterioration
Capacity problems are more critical. Seven pumping stations
are presently operating at or greater than 95 percent of
firm capacity (pumping capacity with the largest pump out
of operation). Three stations (Sunset, Heathfield, and Ken-
more) have measured flows above their capacities, which is
possible because peak flows are partially stored in the in-
fluent sewer.
The Renton Treatment Plant
The Renton treatment plant is situated on the Green/
Duwamish River about 13 miles from the location where the
river enters Elliot Bay. A detailed description of the Renton
plant may be found in Metro's Technical Memo No. 1, from
which the following discussion has been summarized.
The plant is designed to treat an average of 36 million
gallons per day (MGD) average dry weather flow (ADWF) and
an average of 96 MGD peak wet weather flow (PWWF). The waste-
water entering the plant is expected to bring about 75,000
pounds per day of biochemical oxygen demand (BOD) and 93,000
pounds per day of suspended solids (SS). This is equivalent
to about 250 milligrams per liter (mg/1) of BOD and 310 mg/1
SS. The treated wastewater entering the river is currently
required to have no more than 15 mg/1 of BOD and 15 mg/1
SS.
To reduce pollutant loads to meet the discharge limita-
tions (see Table 1-3), the Renton plant has several treatment
steps as shown in Figure 1-4. Pollutant removal includes
pretreatment, primary treatment (sedimentation), secondary
treatment (activated sludge), and chlorination/dechlorination.
The pretreatment process settles coarse grit and uses
bar screens to remove the materials larger than 0.75 inch.
The objects captured by the screens are transferred hydrauli-
cally to a grinder which shreds and pulverizes the screenings
so that they may be returned to the influent flow ahead of
the bar screens. Raw sewage pumps lift the wastewater to
two aerated grit removal channels where the water is aerated
17
-------
Table 1-3. Existing and Proposed Discharge Limitations for
the Renton Wastewater Treatment Plant
Parameter
Flow
BOD5
Suspended Solids
Fecal Coliform
PH
Chlorine Residual
Ammonia
Ammonia (unionized)
Nitrite
Oil and Grease
Cadmium
Chromium (Total)
Copper
Lead
Mercury
Nickel
Zinc
Silver
Units
mgd
mg/1
Ib/day
mg/1
Ib/day
organisms per
100 ml
units
mg/1
Ib/day
mg/1
Ib/day
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/i
mg/1
Existing
Limit
38
153
4,7553
15
4,755
200
6.5-8.5
0.5
—
—
—
—
—
0.004
0.02
0.04
0.05
0.0015
0.03
0.09
—
Proposed
Limit 1
48
104
2,9004
15
4,300
200
6.5-8.5
0.008
2,700
0.08
24.02
0.24
15
0.0016
0.10
0.008
0.021
0.0002
0.10
0.004
0.00068
Typical
Amount /
39
93
4,9903
11
3,730
57
6.5-7.1
0.26
—
16.6
—
—
2.4-20
<0.004
0.015
0.03
0.009
0.0013
0.019
0.05
—
Source: 1 DRAFT NPDES Waste Discharge Permit for the Municipality of
Metropolitan Seattle, Renton Sewage Treatment Plant (March 1980)
2 NPDES Discharge Monitoring Report for the Renton Treatment Plant
(January 1979-March 1980) .
Total
Carbonaceous
18
-------
CHLORINE
AIR
AIR
ALUM
CHLORINE
DECHLORINATION
CHEMICALS
SCREENING
SEPTIC TANK
PUMPIN6S
P8MP
PREAERATION
COARSE
FINE
GRIT
i r
.SEDIMENTATION
'///////A
ACTIVATED
SLUDGE
AERATION
__^_
SEoMENTATION'
CHLORINE
CONTACT
EFFLUENT
TO
"- GREEN/
DUWAMISH
RIVER
GRIT
TO
LANDFILL
-*- SLUDGE 6 SCUM TO
WEST POINT
TREATMENT PLANT
FIGURE 1-4. PROCESS SCHEMATIC OF RENTON TREATMENT PLANT
-------
and fine grit is removed. The grit is dewatered and moved
by a mechanical screw conveyor to storage hoppers. The coarse
grit is periodically collected manually and placed in the
hoppers. Grit is hauled to a sanitary landfill for disposal.
Water that has been screened and degritted flows by
gravity through two aerated channels to the eight primary
sedimentation basins (clarifiers). In primary treatment,
the water velocity is slowed so that all of the heavy material
(sludge) can settle and the light floatable material (scum)
can rise to the surface. The primary sludge is collected
by scrapers on the bottom of the sedimentation basins. Sludge
is currently pumped and metered continuously into a force
main for transmission to the West Point treatment plant.
The scum is collected by skimmers and delivered to scum pumps
where it is discharged to the sludge force main.
Primary effluent from the sedimentation basins flows
into collection channels that direct the water to either
the activated sludge process or, in emergencies, directly
to chlorination and discharge. In the activated sludge pro-
cess, the wastewater is distributed into two horizontally
baffled aeration tanks and mixed with the activated sludge.
Six air blowers supply air to the aeration tanks, and the
concentration of air is controlled by a system of dissolved
oxygen probes, which measure the amount of oxygen in the
aeration tanks. Dissolved oxygen allows the organisms present
in the activated sludge to convert about 50 percent of the
oxygen-demanding materials in the settled sewage to water
and carbon dioxide, and to convert almost 50 percent more
to more activated sludge organisms.
The mixture of sludge organisms and treated wastewater
(mixed liquor) overflows from the aeration tanks into an
aerated channel. The channel directs the mixed liquor into
eight circular secondary sedimentation basins. During high
wet weather flows, alum is added to the stream to enhance
sludge removal. Sludge is collected at the bottom of the
basin and scum is skimmed at the surface. Some of the sludge,
return activated sludge (RAS), is returned to the aeration
tank to maintain the activated sludge process. The remainder
of the sludge, waste activated sludge (WAS), is mixed with
the primary sludge and pumped to the West Point treatment
plant. The scum collected from the secondary clarifiers
is piped to the influent sewer.
20
-------
Chlorine injectors and diffusers are located at the
secondary effluent collection chambers. Following chlorination,
the effluent flows along a chlorine contact channel; the
long length of this channel provides sufficient time for
the chlorine to disinfect the effluent. Some of the chlori-
nated effluent is used for in-plant process needs and land-
scape irrigation. Any floating material present in the chlorine
contact channel is skimmed and returned to the plant influent.
Sulfur dioxide is injected into the effluent to chemi-
cally neutralize any toxic chlorine before disposal. From
the chlorine contact channel, the effluent passes over a
weir, where the rate of flow is measured; the effluent is
then discharged to the Green/Duwamish River via an outfall
diffuser located on the river bed.
Wastewater and Sludge Characteristics
Wastewater. The Renton treatment plant was originally
conceived to treat an ultimate flow of 144 MGD. Currently,
the Renton treatment plant units are all conservatively sized
to treat an average 36 MGD with the exception of the head-
works, influent sewer, and influent pumping and screening
structures, which can accommodate the ultimate ADWF of 144
MGD, and the primary units, which are designed to treat an
average of 72 MGD. Hydraulically, the other processes in the
plant may treat an ADWF of 48 MGD; however, BOD and solids
concentrations limit the activated sludge processes to a
capacity of 36 MGD.
Figure 1-5 and Table 1-4, which present historic flow
and wasteload data, indicate that the monthly average flow
was below the 36 MGD design flow in 1977. But, the flow
increased to an average 39.4 MGD in 1978, to 38.4 MGD in
1979, and to 42.5 MGD during the first quarter of 1980. The
BOD and SS loadings have also increased. The average BOD
entering the plant increased from 84,900 pounds per day in
1979 to 141,800 pounds per day during the first quarter of
1980, significantly greater than the design BOD loading of
75,000 pounds per day. Similarly, the SS entering the plant
increased from 103,900 pounds per day in 1979 to 117,100
pounds per day during the first quarter of 1980, significantly
greater than the design SS loading of 93,000 pounds per day.
21
-------
60
50
40
30
20
10
36 MOD
Plant Design Flow
1977
1978
1979
YEAR
1980
1981
* MONTHLY AVERAGES OF DAILY INFLUENT FLOW
SOURCE: METRO, 1981
FIGURE 1-5. RENTON TREATMENT
PLANT WASTEWATER FLOWS*
-------
Table 1-4. Influent and Effluent BOD* and SS* Quantities
Month
1979
January
February
March
April
May
June
July
August
September
October
November
December
AVERAGE
1980
January
February
March
Flow
mgd*
39.33
48.51
41.90
38.12
36.86
35.50
33.55
33.22
34.08
34.61
39.55
50.84
38.4
44.48
42.10
40.85
BOD, 1000
Influent
105.4
123.4
141.5
137.6
105.1
86.1
81.1
73.4
79.6
73.6
87.9
95.8
84.9
99.6
247.5
78.4
Ib/day
Effluent
5.4
13.0
6.9
4.2
5.5
4.4
3.6
3.3
3.5
3.7
3.7
5.4
5.2
3.8
3.7
3.6
SS, 1000 Ib/day
AVERAGE
42.50
141.8
3.7
Influent
142.7
204.3
208.6
169.7
130.0
103.6
99.1
83.4
96.6
97.9
108.1
127.2
130.9
134.8
112.3
104.3
117.1
Effluent
5.1
13.9
4.2
2.5
2.3
1.6
1.6
2.4
2.0
2.7
2.9
4.8
3.8
4.6
2.3
2.6
3.2
*NOTE
BOD - Biochemical Oxygen Demand
SS - Suspended Solids
mgd - million gallons per day
Source: Metro internal nemos: Renton Treatment Plant Monthly Process
Analysis (for the above months) .
23
-------
The Renton treatment plant has been operating in a stressed
mode for nearly 2 years. However, the effluent BOD and
SS leaving the plant and entering the river have generally
been within the existing state discharge limitations (see
Table 1-4). The requirements are 4,755 pounds per day of
BOD and 6,338 pounds per day of SS. During 1979 the average
effluent BOD loading was 5,200 pounds per day and the average
effluent SS loading was 3,800 pounds per day. For the first
quarter of 1980, the BOD loading was 3,700 pounds per day,
and the SS loading was 3,200 pounds per day. The plant is
meeting its discharge limits because it was designed with
several back-up measures to provide reliability during higher
flows. Among the back-up features are flow storage in the
influent sewer, inherent resiliency of the activated sludge
process, use of chemicals to improve sludge settling, pro-
viding secondary treatment to only part of the flow, and
the capability of diverting 2-4 MGD to the West Point plant
via the pressurized sludge line.
Besides BOD and SS, other characteristics of the waste-
water have an influence on the quality of the discharge from
the plant. Among those characteristics are nitrogen, phos-
phorus, pH, temperature, grease and metals. Typical concen-
trations of these other constituents during 1979-1980 are
tabulated in Table 1-5.
Sludge. The raw primary sludge and WAS collected during
treatment at the Renton plant are pumped in a force main
to the West Point plant for treatment. No sludge is currently
treated at the Renton plant. Figure 1-6 shows the amounts
of sludge that have been sent to the West Point plant for
the period January 1978 through March 1980. Metro does not
compile separate data on the quality of Renton plant sludge.
Renton treatment plant sludge makes up approximately
40 percent of the influent SS to the West Point plant, and
is creating severe operational problems for the West Point
plant. The sludge is pumped from the Renton plant as dilute
as possible in order to keep the sludge force main detention
times short, thus minimizing sulfide corrosion and odor problems
at the force main discharge points and maintaining the flow
in the gravity collection sewer as high as possible.
Existing Chemical Consumption
Four chemicals are used in the Renton system: chlorine,
sulfur dioxide, alum and hydrogen peroxide. Chlorine is
used as a disinfectant to reduce the bacteria population
in the effluent to a safe level. Sulfur dioxide is used
to neutralize any of the residual chlorine not used up in
24
-------
Table 1-5. Renton Treatment Plant Effluent Characteristics
January 1979 - March 19801
Parameter
Flow
BOD5
SS
NH3-N
Phosphorus2
Temperature2
pH
Dissolved Oxygen2
Grease2
Chlorine Residual
Fecal Coliform
Mercury
Cadmium
Copper
Lead
Zinc
Nickel
Chromium (Total)
Units
Average
mgd
mg/1
Ib/day
mg/1
Ib/day
mg/1
mg/1
op
units
mg/1
mg/1
mg/1
Organisms per 100 ml
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
33-51
5-17
1,360-35,000
5-26
1,580-10,000
11.3-13.9
3.2-7.1
56-73
6.1-8.5
4.5-8.9
2.4-20
0.20-0.29
14-116
0.0003-0.0034
0-<0.004
0.02-0.05
0.001-<0.02
0.03-0.10
0.008-0.03
0.005-0.03
39
9
4,990
11
3,730
13.7
4.3
—
6.5-7.1
7.0
—
0.26
57
0.0013
<0.004
0.03
0.009
0.05
0.019
0.015
Source: 1 NPDES Discharge Monitoring Report for the Renton Treatment Plant
2 Metro, 1979d.
25
-------
o
Q_
O
o
o
I
O
UJ
Q_
0.
200-
180 •
160 •
140-
120-
100-
80 -
60 -
40-
20 •
0-
RAW SLUDGE
WAS
i I i i I i i I i i i I I I I i I I I 1 I 1 r I \ \ \ i r
JF MAMJJASONDJ FMAMJJASONOJFU A M J
1978
1979
1980
SOURCE^ METRO, I979d
FIGURE 1-6. POUNDS OF SLUDGE PUMPED TO WEST POINT
-------
the disinfection process, since residual chlorine discharged
to the receiving water can be toxic to fish. Alum is used
as a coagulant to enhance solids removal in the secondary
sedimentation step; alum is used only when the flow in the
plant is greater than the design capacity. Finally, hydrogen
peroxide is introduced to the sludge force main to control
the effects of corrosion of the sewer pipe by hydrogen sulfide.
Chlorine and sulfur dioxide are used in the greatest
quantities because they are added continuously; alum and
hydrogen peroxide are used in smaller amounts because they
are used on an intermittent basis. During January 1979 through
March 1980, chlorine was used at a rate of 27 pounds per
million gallons (190 tons per year) and sulfur dioxide was
used at a rate of 9 pounds per million gallons (67.5 tons
per year). Alum is used intermittently during high flow periods,
and during 1979 was used at an average rate of 9 pounds per
million gallons (78 tons per year). Because flows are con-
tinually increasing, even greater quantities of alum will
be required in the future; the estimated alum use in 1981
is about 28 pounds per million gallons (243 tons per year).
About 9,000 gallons of hydrogen peroxide was required in
1979 and about the same amount should be required in 1980.
Existing Energy Use
In many wastewater treatment plants, energy needs are
partially met by gas produced on-site by the digestion of
sludge. Since the Renton treatment plant sludge is pumped
to the West Point plant, the Renton plant's energy needs
are met exclusively by purchased electricity. Figure 1-7
graphically depicts the energy use and costs at the Renton
plant from 1971 to present. As shown in this figure, the
electrical energy used has remained fairly constant through
the years, due mainly to energy conservation efforts. In
spite of these conservation efforts, rapid escalation in
the unit power rate has resulted in a very significant in-
crease in the total power bill. Figure 1-7 also illustrates
that the power bill increased at a rate significantly greater
than the plant flow. In the future, the plant power bill
can be expected to generally increase in proportion to the
power rate, because conservation efforts are reaching the
maximum obtainable limits at the existing plant. Therefore,
future increases in the plant power bill will be even more
dramatic than in the past.
27
-------
00
60
50
40
cc
>- 30
a:
o
o
20
a.
10
6.0
5.0
4.0
cc
UJ
a_
co
CJ
EC
3.0
2.0
1.0
600,000-1
DRY WEATHER
PLANT FLOWS
FIGURE 1-7 RENTON TREATMENT PLANT ELECTRIC POWER COST VS. TIME
o
—1
33
O
co
SOURCE METRO, PERS COMM , 1 98O
-------
Existing Costs of Wastewater Treatment
The cost of treating wastewater is generally proportional
to the amount of wastewater treated: when more wastewater
is treated, more chemicals are required, more labor and
materials are needed to maintain the equipment, and more energy
is needed to add air to the water. Table 1-6 displays the
historic costs of wastewater treatment at the Renton plant.
The Nonsewer Area
About 75 percent of the study area is not sewered. The
residents of this area rely primarily on conventional septic
tanks and drainfields for wastewater treatment and disposal.
Authorities having the main responsibility for regulating
on-site wastewater disposal are the health departments in
King, Snohomish and Pierce Counties. King County health
officials have estimated that from 50,000-100,000 such systems
may be in use, with 80,000 a realistic number (Metro, 1979d).
However, most of the soil types in the nonsewer area have
severe wastewater disposal limitations due to insufficient
depth, slow permeability, flood hazards, or high groundwater.
Septic tanks, as part of their regular maintenance,
need to be pumped to remove the solids accumulation. If
all on-site systems were being pumped on a once-in-three
year basis, approximately 27 million gallons of septage per
year would be generated (Metro, 1980d). The Renton treat-
ment plant receives most of the septage from the study area.
Recent billing records at the Renton plant show that about
11 million gallons of septage are being treated on an annual
basis. A full-scale septic tank maintenance program would
therefore increase considerably the septage quantities re-
ceived at the Renton plant.
Some "alternative" systems (other than septic tanks)
have been installed in the study area. Those systems in-
clude composting toilet and mound systems. However, the
alternatives are relatively new and their performance has
not been fully evaluated.
29
-------
Table 1-6. Costs of Wastewater Treatment
at the Renton Plant
Year
1974
1975
1976
1977
1978
1979
Average
Daily Flow
mgd
28.42
31.74
30.84
32.90
39.45
40.27
Operation &
Maintenance
$/mg
76.70
29.95
90.99
106.99
112.62
129.75
Depreciation
$/mg
.29.14
47.34
47.50
49.43
49.43
49.43
Estimated
Transmission
$/mg
27.80
10.85
32.97
38.77
40.81
47.02
Total
Cost
$/mg_
133.64
148.14
171.46
195.19
202.86
226.20
SOURCE: Metro, 1980, pers. comm.
30
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Chapter 2
DESCRIPTION OF RECOMMENDED PROGRAM AND EIS APPROACH
Introduction
This chapter describes the Metro recommended wastewater
management program for the study area. Separate sections
first describe the process for selecting the recommended
program, and the various elements of the recommended program.
The approach to the EIS evaluation of the recommended pro-
gram and alternative programs is then described.
Process for Selecting Recommended Program
In the Draft EIS, four wastewater management alternatives
for the study area were evaluated in detail. These were
Alternative A-l, involving continued discharge of Renton
effluent to the Green-Duwamish River with nitrification;
Alternative A-3, involving construction of a tunnel and outfall
to Puget Sound off Three Tree Point/Seahurst Park; Alter-
native A-5, involving construction of a tunnel and outfall
to Alki Point/Duwamish Head; and Alternative B-l, involving
continued discharge of Renton effluent to the Green-Duwamish
River with nitrification, plus construction of a new Kenmore
treatment plant to treat flows from the north part of the
study area. A detailed description of each of the four final
alternatives is presented in Chapter 4 of the EIS.
In the Draft Wastewater Management Plan for the Lake
Washington/Green River Basins, Metro selected Alternatives
A-3/A-5 as the preferred long-term wastewater management
program. Although Alternative A-l was the least cost alter-
native, Alternatives A-3/A-5 were judged to have "over-
riding benefits" justifying the increased costs. The over-
riding benefits were improved water quality protection and
reduced operation and maintenance costs. The process of
selecting Alternative A-3/A-5 as the preferred program is
described in greater detail in Chapter 4 of the EIS.
Alternatives A-3/A-5, as recommended in Metro's draft
plan, called for expansion of the Renton treatment plant
to 99 MGD to service the entire sewer service area; con-
struction of solids handling facilities at the Renton site;
wastewater treatment with conventional secondary processes;
31
-------
and diversion of treated wastewater by means of a tunnel
to either the Three Tree Point/Seahurst Park area or the
Alki Point/Duwamish Head area. (The Duwamish Head alter-
native was not considered in the draft plan or EIS, but has
been considered in the final plan and EIS.)
Metro subsequently recommended a selected tunnel and
outfall route to Puget Sound in the Final Wastewater Manage-
ment Plan. Six alternative routes were considered: Seahurst
Park (Route A), Lake Burien (Route B), Three Tree Point (Route
C), West Duwamish (Route D), East Duwamish (Route E), and
Duwamish Head (Route F). The final plan considered differ-
ences in costs, land use impacts, and water quality benefits
among the alternatives, and concluded that Seahurst Park
route should be selected. Key reasons cited by Metro for
this decision were that: 1) even considering potential savings
from sharing the costs of an Alki outfall with other proposed
Metro projects, a Seahurst Park alternative would still be
$32.2 million less expensive; 2) implementation of the projects
which could result in cost sharing is uncertain; 3) adverse
land use impacts would be encountered along any of the routes;
and 4) the Seahurst Park site is a more than adequate receiving
water.
Description of the Recommended Program
Under the recommended program described in Metro's final
plan, the Renton treatment plant would be expanded to 72 MGD
to treat year 2000 flows from the existing Renton service
area. Wastewater flows from the Renton service area were
40 MGD in 1980, and are projected to increase to 59 MGD by
1990 and to 73 MGD by the year 2000. The Renton plant service
area recommended by Metro's final plan is shown in Figure 2-1.
It should be noted that Metro's draft plan recommended
expansion of the Renton treatment plant to 99 MGD, with a
first phase expansion to 72 MGD, to treat flows at Renton
from sewered areas currently tributary to West Point, as
well as flows from sewered areas tributary to the Renton
plant. This required the construction of the Redmond and
North Creek/Hollywood connections to transfer flows from
the West Point service area to the Renton plant. Metro has
since postponed a recommendation on the Redmond and North
Creek/Hollywood connections until after a decision is made
on the West Point secondary treatment waiver application
currently being reviewed by EPA. Accordingly, a final decision
on these collection facilities will follow the West Point
waiver decision process, and may include a supplemental
facilities plan and supplemental EIS for the West Point plant.
Metro has indicated that the final plan retains flexibility
to accept Redmond and North Creek/Hollywood connection flows.
Alternatively, a future decision could be made to build a
Kenmore plant to treat waste flows from the north part of
the study area beyond the year 2000.
32
-------
j> >Jl>^ SNOHOMiSH\COUNTY
STUDY AREA BOUNDARY
SEWER SERVICE AREA
TO BE SERVED BY
RENTON TREATMENT PLANT
NORTHERN SEWER SERVICE AREA
v.. TREATMENT SITE TO BE DETERMINED
m (OPTIONS INCLUDE; WEST POINT,
RENTON, AND KENMORE
ON-SITE OR COMMUNITY
WASTEWATER DISPOSAL AREA
SEWER SERVICE MAY BE EXTENDED
INTO THESE AREAS ONLY AFTER
FORMAL AUTHORIZATION FROM THE
LOCAL LAND USE AGENCY
: NON-METRO SEWER
: SERVICE AREA
SOURCE: METRO, 1981
FIGURE 2-1. RECOMMENDED RENTON
SERVICE AREA
33
-------
Effluent Stream
Under the recommended program, the effluent quality
from the Renton plant would be derated for disposal to Puget
Sound because of the sound's greater dilution ability and
assimilative capacity compared to the Green-Duwamish River.
Currently, effluent quality averages 10 mg/1 suspended solids
and 15 mg/1 BOD. Under the recommended program, the treat-
ment plant would be designed to meet the 30 mg/1 suspended
solids, 30 mg/1 BOD requirement of conventional secondary
treatment. This would achieve removal of 85 percent of both
BOD and suspended solids.
The various elements of the recommended treatment process
improvements at the Renton treatment plant are listed in
Table 2-]. which orovides the costs for each element.
Solids Stream
The recommended program provides for solids handling
facilities to be installed at the Renton plant. Renton sludge
would no longer be conveyed to the West Point plant for pro-
cessing. The various elements of the proposed solids handling
system are listed in Table 2-2, which provides costs for
each element.
Primary sludge would be gravity thickened and waste-
activated sludge would be thickened by dissolved air flota-
tion prior to digestion. Anaerobic digestion would be used
to stabilize the sludge. The sludge would then be dewatered,
following which Metro assumes it will be used in a land appli-
cation program including silviculture, soil improvement,
and composting. These and other alternatives for ultimate
use or disposal of Renton sludge are described in Chapter 4;
Metro is currently developing a sludge management program
for all its treatment plants, and a separate EIS will be
prepared for this program describing the impacts of each
alternative.
Methane gas from the anaerobic digestion process will
be recovered and used for energy supply at the Renton plant.
Metro indicates that gas recovery and reuse will not make
the Renton plant energy self-sufficient, but will signifi-
cantly reduce its demand on external energy sources.
34
-------
Table 2-1. Liquid Stream Design Parameters,
30/30 Effluent
Unit
Primary Sedimentation System
Number
Width, ft.
Length, ft.
Average water depth, ft.
Detention time, AWWF, hours
Overflow rate, AWWF, gal/sq ft/day
Secondary Aeration System
Tanks
Number
Width each pass, ft.
Length each pass, ft.
Average water depth, ft.
Detention time, AWWF, hours
BOD loading, Ib applied/cu ft/day
Secondary Clarification System
Number
Diameter, ft.
Average water depth, ft.
Detention time, AWWF, hours
Overflow rate, AWWF, gal/sq ft/day
Existing
8
34
164
9
2.25
860
8
30
317.5
15
6.42
42.6
8
100
14/18
5.4/5.7
572
72 mqd
a
1.0
1,600
4
30
317.5
15 b
4.3°
76
8
100
18
5.7
572
Dependent upon full scale test results.
Derating increases module from 18 to 24 mgd
Four at 14 feet, four at 18 feet.
SOURCE: Metro 1981.
35
-------
Table 2-2. Renton Solids Facilities Design Parameters
Unit
Anaerobic digestion
Tanks
Number
Diameter, ft
Sidewater depth, ft
Volume, 1000 cu ft total
Loading
Hydraulic detention,
days average
Total solids,
Ib/cu ft/day
Volatile solids,
Ib/cu ft/day
Gas production
Volatile destruction,
percent
Gas production, cu ft/
Ib volatiles destroyed
Gravity thickeners
Tanks
Number
Diameter, ft
Depth, ft
Loading
Primary solids,
Ib/sq ft/day
Thickened sludge con-
centration, percent
Capture, percent
Dissolved air flotation
Tanks
Number
Diameter, ft
Loading
Waste activated sludge,
Ib/sq ft/day
Thickened solids con-
centration, percent
Capture, percent
Dewatering
Feed solids, percent
Cake, percent
Capture, percent
Dewatering Storage/Blending
Tanks
Volume, 1000 cu ft
Detention time, days
Expansion to
72 mgd
4
120
40
1,810
24
0.12
0.09
55
16
4
45
22
.5
95
4
50
10.3
3
90
3
30
95
1
453
6.5
Mechanical solids facilities
Compatible with dewatering
equipment. Annual average
of 60 dry tons per day.
Energy recovery
To be based on
energy study.
SOURCE: Metro 1981.
36
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Effluent Disposal
The recommended program calls for construction of a
tunnel and outfall off Seahurst Park. The proposed route
is shown in Figure 2-2. The various elements of the tunnel
and outfall are listed in Table 2-3; cost estimates are shown
in Table 2-4. Two pump stations would be required, one at
the treatment plant site and another at the tunnel's western
portal at Seahurst Park. The tunnel and outfall have been
designed to accommodate average flows of 144 MGD and peak
flows of 325 MGD (the difference between 144 and 325 MGD
represents capacity for storm flows). These flows represent
50-year flows from the sewered portions of the entire service
area, including Redmond connection and North Creek/Hollywood
connection flows. If the Redmond and North Creek/Hollywood
connections are not built, then capacity considerably in
excess of 50-year capacity would exist in the tunnel and
outfall.
Costs and Financing
Total capital and operation and maintenance costs for
the recommended program are listed in Table 2-4. Present
worth costs are approximately $225 million. Funding for
these costs would be provided by a combination of federal
and state construction grants, local revenue bonds, and
monthly sewer service fees.
For approved capital facilities, for which funding is
available, federal grants can pay up to 75 percent of the
eligible cost, state grants up to 15 percent, and local funds
10 percent. If the project is classified as innovative and
alternative by the EPA, the federal grant can increase to
85 percent, the state grant becomes 9 percent, and the local
share decreases to 6 percent. In the past, Metro has sold
revenue bonds to finance the local share of the capital costs
and then repaid these bonds using a portion of the Metro
monthly charge.
Annual operation and maintenance costs are paid for
by Metro, and no grant funds are involved. Operation and
maintenance costs are paid for by a portion of the monthly
charge collected by Metro.
Metro has developed a funding scenario to estimate
the impacts of its plan on monthly sewer rates. This scenari
assumes that the following items would be eligible for state
and federal grants: capital costs of expanding the treatment
plant to accommodate existing wastewater flows; capital costs
of constructing solids processing facilities to accommodate
solids currently transferred to the West Point plant; and
capital costs for constructing that portion of the tunnel
and outfall to Puget Sound which accommodates existing waste-
water flows.
37
-------
TUMCl CONSTRUCTION
OftHCUT CONSTRUCTION
HOUIKD
PUMP STATION
SOURCE: METRO, 1981
FIGURE 2-2. PROPOSED TUNNEL/
OUTFALL ROUTE
-------
Table 2-3. General Tunnel/Outfall Information
Route
Seahurst
Park*
Element
Outfall
Tunnel
Force
Mains
Pump
Stations
Capacity
144 mgd
average flow
325 mgd
peak flow
144 mgd
average flow
325 mgd
peak flow
144 mgd
average flow
325 mgd
peak flow
325 mgd
peak flow
Number and
Estimated Size
one at 96
inches
one at 120
inches
two at 72
inches
two at
10,000
sq. ft.
Approximate
Length, Ft.
3,000
27,000
4,000
Approximate
Depth, Ft.
200 +
(dif f user)
100-400
minimum 4
to 6 feet
of cover
surface
structure
* The Seahurst Park tunnel/outfall route requires the acquisition of a construction
staging site (approximately one acre in size) at each tunnel portal. Easements
will also be required at three separate sites along the tunnel route identified
in Figure 3-6.
SOURCE: Metro 1981.
-------
Table 2-4. Cost of Recommended Improvements'
Project Cost,
Item Million $
Liquid Stream (72 mgd)
Primary 0
Aeration 13 . 1
Clarifiers 16.8
Chlorination and dechlorination 0 . 4
Subtotal 30.3
Solids Stream (72 mgd)
Gravity thickening 3.1
DAF 6 . 7
Anaerobic digestion 22.7
Dewatering 8 . 4
Gas recovery 5.7
Mechanical solids handling 2 . 0
Subtotal 48.6
Effluent Disposal (144 mgd)
Outfall 9.2
Tunnel 102.2
Force Main 7 . 6
Pump stations 21.0
Land and easements 0.2
Subtotal T40.2
Total Project Cost 219.1
Annual 0/Mb 5.8
Present Worth 225.4
3 Based on ENR-CCI = 3500, mid-1980 USWRC discount rate
7-1/8 percent.
Average over the planning period.
SOURCE: Metro 1981.
40
-------
Metro has developed a funding scenario which assumes
that 33 percent of the state and federal construction grants
available in Washington would be allocated to Metro. Future
monthly sewer rates, given this scenario, are shown in Figure
2-3. This graph shows the amount of increase attributable
solely to the Renton program, and a range of increases attri-
butable to alternative improvements at the remaining Metro
plants discharging to Puget Sound. As shown, monthly sewer
rates could vary between about $15 per month to about $33
per month, depending on the decision made regarding Metro's
Puget Sound plants.
Alternatives for the Nonsewer Area
Most residents in the nonsewer portion of the study
area will continue to use on-site individual or small community
wastewater treatment and disposal methods over the next 20
years. Although many of the soils in King County have been
found to have severe limitations, on-site methods have been
successfully used. The traditional septic tank/leach field
system can be used, but diligence must be used in the design,
construction, inspection, and maintenance of the systems.
In the past, on-site systems have been viewed as a short-
term solution for wastewater treatment. In 1977 the King
County Council called for the strengthening of regulations
to improve performance of on-site systems, thus, moving in
the direction of long-term use of on-site systems. The Seattle-
King County Health Department in 1980 adopted revised regula-
tions governing on-site systems which recognize these systems
as long-term waste management options. It should be noted
that Metro presently has no on-site wastewater system manage-
ment responsibilities, but rather views itself as a facilitator
in resolving on-site system issues.
Metro's Wastewater Management Plan sets forth a series
of recommendations, for consideration by local health and
landuse agencies, designed to protect water quality and public
health in nonsewer areas. These recommendations, which assume
that on-site methods will continue to be the preferred method
of wastewater management in the nonsewer areas, may be summarized
as follows:
o Establish a comprehensive program for design, con-
struction, and maintenance of on-site and community
systems.
o Identify an areawide management agency and imple-
ment a program demonstrating long-term commitment
to management of nonsewer areas.
41
-------
tvj
01
en
3-1
32
30
28
26
24
22
20
18
16
14
12
10
8
6
4
2
FULL SECONDARY
TREATMENT
PREFERRED FACILITY
PLAN
FULL UTILIZATION
OF WEST POINT
INCREMENT DUE TO
RENTON SYSTEM
IMPROVEMENTS
CONTINUED OPERATION
OF EXISTING
FACILITIES
1982
1983
Assumptions:
1) Inflation rate of 11% annually from 1981 to 1982 and 10% annually thereafter.
2) Rates are based upon 30 year revenue bonds at 10% interest.
Given the stated assumptions, the actual monthly rate will be within the shaded
band presented above. The exact amount will depend upon decisions made related
to Metro's other treatment plants. Options being considered include: "full
utilization" of West Point; the Preferred Facilities Plan (January, 1979)? and
secondary treatment at all Metro plants.
SOURCE
METRO, 1981
FIGURE 2-3. ESTIMATED FUTURE METRO MONTHLY
RATE (ASSUMING METRO RECEIVES 33% OF
AVAILABLE STATEWIDE FUNDS)
-------
o Establish on-site management zones in nonsewer areas
where system performance or soil condition is poor.
o Establish a routine performance monitoring system.
o Further strengthen existing rules and regulations
to emphasize proper design and construction.
o Provide adequate staffing and funding for on-site
wastewater management programs, and provide adequate
enforcement of rules and regulations.
o Encourage experimentation with alternative technologies
o Establish public education program emphasizing the
long-term nature of on-site systems and proper design,
construction, and maintenance.
Triggering Mechanism
The triggering mechanism is a monitoring program proposed
by Metro's Wastewater Management Plan to accomplish three
purposes: 1) to provide advance notice for needed expansions
or additions to the Metro sewerage system, 2) to monitor
the performance of on-site systems in nonsewer areas, and
3) to monitor Puget Sound water quality near the outfall.
To accomplish the first purpose, monitoring of popula-
tion, wastewater flow, and sewer service area changes is
proposed. The triggering mechanism will act as a timing
device to indicate when a decision must be made to construct
an expanded or new treatment plant, pump station, or inter-
ceptor sewer. Possible courses of action include taking
some nonstructural action (e.g., flow reduction, modifying
facility operation), as well as structural alternatives.
Monitoring the performance of on-site systems is pro-
posed to be the joint responsibility of local land use and
health agencies, and Metro. It is assumed that local land
use and health agencies will provide the necessary assessment
of on-site system performance. Metro would identify existing
or potential water quality problems through its lake and
stream monitoring program. When a problem area is identified,
appropriate local land use and health agencies would be asked
to chair a meeting to verify the problem and choose an appro-
priate course of action. Alternative courses of action in-
clude establishing an on-site wastewater management district,
developing a community wastewater system, installing a new
on-site technology, connecting to the centralized sewerage
system, or taking no action other than further study or evalu-
ation.
43
-------
Metro has also proposed a water quality monitoring plan
for the Puget Sound outfall. Monitoring is designed to ensure
that water quality standards are met and to give advance
warnings if any problems develop.
Metro proposes the preparation of an Annual Wastewater
Management Plan update. This update would include a status
report on the Renton sewerage system and nonsewer area moni-
toring .
Near-Term Collection System Projects
In its Wastewater Management Plan, Metro has identified
certain collection system improvements within the study area
that it believes should be undertaken as soon as possible.
Fourteen projects have been categorized into two groups:
projects to be initiated and projects in progress. The 14
projects are listed in Table 2-5.
Approach to EIS Evaluation of Recommended
Program and Alternatives
Program Elements Evaluated
Comprehensively evaluating the direct and secondary
environmental impacts of long-term wastewater management
alternatives for the 620-square-mile study area is a complex
undertaking. The general approach taken here is to first
briefly describe the study area environment (Chapter 3) and
the four final long-term alternatives considered by Metro
(Chapter 4). Then, separate chapters evaluate the con-
struction and site-related impacts of components included
in the four final long-term alternatives (Chapter 5); the
operational impacts of these long-term alternatives (Chapter 6);
and the secondary growth-related impacts are common to all
alternatives (Chapter 7).
The triggering mechanism, the near-term collection system
projects, and the nonsewer area alternatives proposed as parts
of the Metro Wastawater Management Plan are not separately
assessed for impacts in the EIS. The triggering mechanism
is essentially a mitigation measure for assisting in the
implementation of the long-term program, and for monitoring
the performance of on-site systems in nonsewer areas; thus,
there are beneficial impacts, but no adverse impacts, attri-
butable to the triggering mechanism. Near-term collection
system projects are not part of the current decisions which
44
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Table 2-5. Near-Term Collection System Projects
Projects to be Initiated
Facility Action
Kenmore Pump Station Construct interim facility to alleviate
capacity/reliability problems,
V7est Valley Inter-? Contractual obligation to construct
ceptor new interceptor.
Eastgate Trunk Construct facilities to alleviate
capacity problem.
Mill Creek Relief Contractual obligation to construct
Sewer new sewer.
Medina Pump Station Construct facilities to alleviate
capacity/reliability problems.
Riverton Pump Station Construct facilities to alleviate
capacity/reliability problems.
Wilburton Pump Construct facilities to alleviate
Station capacity/reliability problems.
Projects in Progress
Facility Action
Issaquah Creek Contractual obligation to construct
Interceptor new interceptor.
Juanita System Construct facilities to alleviate
Upgrade capacity/reliability problems.
May Creek Interceptor Construct new interceptor at local
agency request.
Mercer Island System Construct facilities to accommodate
Realignment 1-90 construction.
Sunset/Heathfield Construct facilities to alleviate
System Upgrade capacity/reliability problems.
Sweyoloken Pump Construct facilities to alleviate
Station capacity/reliability problems.
Wilburton Siphon Construct new barrel to alleviate
capacity problem.
45
-------
are to be made a part of the Renton facilities plan; environ-
mental review of these projects has or will be accomplished
separately from this EIS process. Lastly, alternatives for
the nonsewer area are not separately assessed here because
they are not presented as grant-fundable projects by Metro
at this time; however, environmental impacts of and mitiga-
tion measures for on-site systems in the nonsewer area are
assessed in the secondary groundwater impacts section of
the EIS.
Differences in Impacts Between Recommended Program and
Alternative A-3
The recommended program, as noted previously in this
chapter, defers the decision as to hookup of the West Point
sewered area to the Renton plant. Therefore, an expansion
of the Renton plant will be made only to 72 MGD to treat
year 2000 flows. A decision to construct the Redmond and
North Creek/Hollywood connections will not be made at this
time. The recommended program is identical to Alternative
A-3 as originally defined, except that year 2000 treatment
plant capacity is 72 MGD (versus 99 MGD under Alternative A-3)
and the connection sewers are not built.
If a future decision is made to continue the West Point
deemphasis policy, the recommended program would lead to
implementation of Alternative A-3. For this reason, the
detailed evaluations in this EIS focus on Alternative A-3f
rather than the recommended program, and compare the impacts
of Alternative A-3 to other long-term alternatives. The
analysis in the EIS is a maximum service area analysis,
assuming the sewered portions of the entire study area would
connect to the Renton plant.
What impacts would result if the alternative decision
is made to abandon the West Point de-emphasis policy? In
this case, the recommended program would become the "year
2000 program" for the Renton treatment plant. Three major
changes in impacts would occur. First, the site impacts
at the Renton plant would be reduced because less new con-
struction would be needed. Second, water quality effects
of Renton effluent on Puget Sound would be less because only
72 MGD would be discharged through the Renton tunnel and
outfall, compared to 101 MGD under Alternative A-3; it should
also be recognized, however, that the 29 MGD difference wpuld
be discharged via the West Point outfall, where it would
receive only primary treatment if a waiver for the West Point
plant is granted. Third, the Redmond and North Creek/Hollywood
connections would not be built, avoiding the construction
and site-related impacts associated with these sewers.
46
-------
Deferring the decision on the status of the West Point
deemphasis policy has certain institutional effects. This
deferral would extend the period of public uncertainty over
the locations for treatment and discharge of north study
area flows. There may be some public confusion or dissatis-
faction over this reconsideraLion of a decision which was
previously reached with public participation. The deferral
will place more importance on the future decision on service
area configuration, since more options would be available
in that decision and more people would therefore be potentially
affected.
47
-------
Chapter 3
DESCRIPTION OF AFFECTED ENVIRONMENT
This chapter presents an overview of the Lake Washington/
Green River Basins study area. The following topics are
covered: climate and air quality; soils, geology, and ground-
water; water resources and water quality; biology and fisheries;
and land use and socio-economics. The intent of these sections
is to acquaint readers unfamiliar with the study area with
its key biophysical and socio-economic features. Existing
environmental conditions are further described in the appendices
to the EIS and in Metro's Technical Memo #2. In addition,
site-specific environmental features (e.g., the Green/Duwamish
River) are described in the background sections of the impact
assessments appearing in Chapters 4 and 5.
Climate and Air Quality
Climate
The climate of the Lake Washington/Green River Basins
study area is characterized by relatively cool, wet winters
and warm, dry summers. The study area's close proximity
to the Pacific Ocean, Puget Sound, and the Olympic and Cascade
Mountains are major factors influencing the climate of the
area.
Annual precipitation within the study area ranges from
35 inches in the lowlands to 100 inches or more in the sur-
rounding mountains. Seventy-five percent of the annual pre-
cipitation occurs during the 6-month period from October
through March. Only 5 percent of annual precipitation falls
during July and August.
Local temperature conditions vary considerably in the
study area according to elevation, solar radiation, and dis-
tance from Puget Sound. Temperatures during the summer months
are generally in the 70s, with occasional temperatures in
the 80s. Winter temperatures are typically in the 40s in
the lowlands and decrease with increasing altitude -- approxi-
mately 3°F for every 1,000 feet of elevation.
Temperature inversions (an increase of temperature with
height) have been recorded every month of the year in Seattle,
but they are most common in October.
49
-------
Air Quality
The concentrations of ozone, carbon monoxide (CO), sulfur
dioxide, and total suspended particulates (TSP) exceed National
Ambient Air Quality Standards (NAAQS) within the central
Puget Sound region. Because of these violations, portions
of the region have been designated nonattainment areas with
respect to these pollutants. In response to the Clean Air
Act Amendments of 1977, an Air Quality Management Plan (AQMP)
was prepared by the Puget Sound Air Pollution Control Agency
(PSAPCA) and the PSCOG (Puget Sound Air Pollution Control
Agency and PSCOG, 1978). The purpose of the AQMP is to present
a coordinated, regional strategy for the attainment of NAAQS.
Vehicular traffic on paved and unpaved roads accounts
for the majority of TSP emissions in both Renton and Kent
(Figure 3-1). Other important sources include mobile emissions
(tailpipe emissions) and fuel combustion.
CO emissions in Bellevue are almost exclusively from
motor vehicles (Figure 3-1). No other sources contribute
significant quantities of CO emissions.
Hydrocarbon emissions contribute to the formation of
ozone. Emissions from motor vehicles are the major source
of hydrocarbons (55 percent) in the Puget Sound region. Other
important sources include solvents, surface coating, petroleum
marketing, and mobile sources other than motor vehicles
(Figure 3-1).
Soils, Geology, and Groundwater
Soils
A map of regional soil associations in the study
is presented in Figure 3-2. Data on generalized capability
class and typical land use of each major soil series and
slope class are presented in Table 3-1. The degree of soil
limitation for wastewater management is also indicated for
on-site septic tank drain fields, sewage lagoons, and for
effluent irrigation systems.
Most of the soils occurring in the study area have severe
limitations for use as septic tank leach fields arising from
their shallow depth, slow permeability or excessive slope.
Moderate to severe soil limitations also exist for irrigation
reuse of treated effluent.
Site-specific soils and geologic constraints along the
proposed tunnel/outfall routes are discussed in General Res-
ponse Number 7 presented in the EIS FOREWORD.
50
-------
WIND EROSION 3%
WOOD PRODUCTS
PROCESSING 6.5%
MISC. 2%
WIND EROSION 3%
TSP-RENTON
TSP-KENT
MOTOR VEHICLES
99,6%
MISC.
0.4%
CARBON MONOXIDE
BEI_i-EVUE
HYDROCARBONS
SOURCE: PSAPCA & PSCOG, 1978
FIGURE 3-1. RELATIVE CONTRIBUTION OF EMISSION
SOURCES-1977 INVENTORY
51
-------
/^c^
LEGEND-
SOURCE: METRO,1»T»«
\ /
V
FIGURE 3-2. GENERAL SOIL ASSOCIATIONS
-------
Table 3-1. Use and Limitations of Some Dominant Soils in the Renton Study Area
Ol
UJ
Limitations for
Septic Tank Leach Fields
Series
Alderwood
Beausite
Buckley
Earlmont
Everett
Indianola
Kitsap
Oridia
Puget
Seattle
Snohomish
Woodinville
Map
Symbol
AgB
AgC
AgD
AkF
BeC
BeD
BeF
Bu
Ea
EvB
EvC
EvD
InA
InC
InD
KpB
KpC
KpD
Os
Pu
Sk
So
Wo
Slope
(%)
0-06
6-15
15-30
25-70
6-15
15-30
40-75
< 3
< 1
0-05
5-15
15-30
0-04
4-15
15-30
2-08
8-15
15-30
< 2
< 1
< 1
< 2
< 2
Agricultural
Capability
Class
IVe
IVe
Vie
vile
IVe
Vie
Vile
IIIw
IIw
IVs
Vis
Vis
IVs
IVs
Vie
Hie
IVe
Vie
IIw
IIIw
IIw
IIw
IIw
Typical
Usaqeb
TPRU
TPRU
TP
T
TPU
TP
T
P,H
PR
TPU
TPU
T
TU
T
T
TP
TP
TP
RPU
RP
PHR
RP1I
RPU
Degree of
hazard
severe
severe
severe
severe
severe
severe
severe
severe
severe
moderate
moderate
severe
moderate
moderate
severe
severe
severe
severe
severe
severe
severe
severe
severe
Type of
hazard0
d,p-
d,p-
d,p-
s,p-
d,p-
d,p-
s,p-
w
f ,w
p+
p+
s,p+
p+
p+
s,p+
p-
p-
s,p-
f ,w
p- , f ,w
w ,o
f ,w,o
w,f
Waste Disposal
Sewage Lagoons Irrigation Reuse
Degree of
hazard
moderate
severe
severe
severe
severe
severe
severe
severe
severe
severe
severe
severe
severe
severe
severe
moderate
severe
severe
severe
severe
severe
severe
severe
Type of
hazard0
s
s
s
s
s
s
s
o
f ,0
p+
p+
s,p+
p+
p+
s,p+
s
s
s
f
f
o
f ,P+,o
f ,0
Degree of
hazard
moderate
moderate
severe
severe
moderate
severe
severe
moderate
moderate
moderate
severe
severe
severe
severe
severe
moderate
moderate
severe
moderate
moderate
severe
moderate
moderate
Type of
hazard0
d
s,d
s,d
s,d
s,d
s,d
s,d
p-,w
f,w
P+
P+
s,p+
p+
P+,s
s,p+
p-,d
P-.s
s,p-
w, f
w,f
o ,w
w,f
w,f
^refers to detailed soil survey map sheets
DT = timber
R = row crops
U = urban development
P = pasture
H = hay crops
"d = shallow depth
f = flooding
o = organic soil layers
p-= slow permeability
[>+= excessive pormoobi lity
s = excessive slope
w = hi.
-------
Geology and Groundwater
The stratigraphy and occurrence of groundwater in surficial
deposits and water-bearing units is described in this section.
The principal water-bearing units in the project area include
sand and gravel of the Salmon Springs drift, advance outwash
(including the Esperance sand) and recessional outwash of
Vashon drift, alluvial floodplain deposits and alluvial fan
deposits. Figure 3-3 depicts a -schematic hydrogeologic cross
section of the Lake Washington/Green River Basins.
Salmon Springs drift deposits consist of up to 200 feet
of sand and gravel with lesser amounts of silt and clay.
These deposits generally form confined aquifers at varying
depths below the ground surface and in many places are the
principal source of groundwater for municipal wells. Vashon
recessional and advance outwash glacial deposits consist
dominantly of sand and gravel. Vashon recessional outwash
deposits occur at the ground surface, are saturated locally,
and are penetrated by many small domestic wells. Advance
outwash deposits occur at or near the ground surface, are
saturated throughout except at the edge of drift plains
where they are typically well drained, and yield small to
moderate amounts of water to wells. These deposits are highly
developed for both domestic and municipal water supplies.
Alluvial floodplain and alluvial fan deposits of sand
and gravel occur along the rivers draining the Cascade Mountains.
These deposits form shallow aquifers which are in hydrologic
continuity with surface water bodies, and yield moderate
amounts of water to numerous small, shallow wells.
Vashon till is very widespread in the project area.
These glacial deposits, with a thickness of about 50 feet,
do not constitute major water-bearing aquifers because they
are dominantly composed of clay and silt and are fairly compact
throughout their thickness. The top portion, however, on
which the Alderwood soil series is developed, is tapped by
many small domestic wells, and is generally loosely compacted
and susceptible to contamination.
Available data indicate that the quality of groundwater
in the study area is good to excellent, although some wells yield
water with objectionable concentrations of iron and/or chloride
and dissolved solids that exceed the national drinking water
standards. The concentration of orthophosphate is high through-
out the study area and typically highest in the deep aquifers.
This is generally attributed to inherent aquifer characteristics
and not to human activities.
Groundwater with objectionable levels of iron is very
common in the study area; however, no areal or stratigraphic
pattern has been found in the occurrence of high iron con-
centrations. The solubility of iron in water increases with
54
-------
1000-
800-
UJ 600-
O «00-
ZOO-
200-
400
ND-
RECENT ALLUVIUM
RECE3SIOIAL CHJTWASH
VASHOII TILL
ADVANCE OUTWASH
OLYHPIA INTERSLACIAL DEPOSITS
SALMON SPRIN6S DRIFT
OLDER 8UATE««ARY DEPOSITS
TERTIARY SEDIMENTARY BEDROCK
CROSS SECTIONS MODIFIED FROM
WASHINSTON STATE WATER SUPPLY
BULLETIN 20, 1963
FIGURE 3-3. SCHEMATIC H YDROG EOLOGIC SECTIONS OF THE LAKE WASHINGTON / GREEN RIVER BASINS
-------
increased levels of acidity. Widespread occurrence of acidic
peat layers in the study area is usually cited as playing
an important role in the occurrence of groundwater rich in
iron.
Groundwater with chloride and dissolved solids concentra-
tions exceeding the standards for drinking water occurs in
two known wells in the study area. Both of these wells are
deep (600 and 1,461 feet), but the specific aquifer tapped
by the wells is not definitely known. Saltwater intrusion
does not appear to be the cause for the poor water quality
in these wells. Rather, the quality characteristics are more
probably caused by connate waters trapped within the water-
bearing strata.
Nitrate in groundwater is of particular interest as
it can be considered as an indicator of contamination caused
by excessive use of fertilizers, heavy concentration of septic
tanks, or failing sewerage systems. The maximum allowable
nitrate level (45 mg/1, NO^) in drinking water is not exceeded
in groundwater from wells in the study area. The nitrate
level typically is less than 1 mg/1 as NO^. Nitrate (NO^)
level, however, is highest in the shallow unconfined aquifers
and decreases progressively in the deeper, generally confined
aquifers. This trend suggests that perhaps land use activities
may be responsible for the higher nitrate levels in the shallow
aquifers.
The contamination potential of the aquifers in the project
area varies significantly and is summarized below:
1. There is little or no contamination potential, from
normal land use practices, for aquifers that occur below
the Vashon till. Shallow wells that tap perched water
bodies in the upper, loosely compacted, portion of the
till as well as wells that tap recessional outwash sand
and gravel deposited on top of the till, however, must
be viewed as susceptible to contamination.
2. Almost all municipal groundwater supplies are obtained
from the deeper aquifers of deltas and alluvial fans.
Contamination of these aquifers by normal land use
practices is unlikely.
3. There are virtually thousands of small, shallow wells
in the project area that are used for domestic purposes.
Most of these domestic wells occur in nonsewered areas,
and are subject to a high risk for contamination.
56
-------
Water Resources and Water Quality
Inland Surface Water
The major surface water bodies in the study area are
shown in Figure 3-4. The largest lakes are Lake Washington
and Lake Sammamish. Lake Washington has a surface area of
32,000 acres and a watershed of 476 square miles, with the
majority of inflow provided by the Cedar River and the Sammamish
River. Lake Sammamish has a surface area of 4,900 acres
and drains a watershed of about 98 square miles, with the
majority of inflow provided by Tibbetts Creek and Issaquah
Creek. Over 80 small lakes are dispersed throughout the
study area, ranging in size from less than 5 to 150 acres.
The major rivers within the study area are the Green-
Duwamish River, the Cedar River, and the Sammamish River.
The Green-Duwamish River, which is about 91 miles long and
drains 483 square miles, is regulated by the Howard Hanson
Dam and Reservoir, with an active storage of 106,000 acre-
feet; the Green-Duwamish River is primarily used for water
supply, fisheries, recreation, and irrigation. The Cedar
River, which is about 50 miles long and drains an area of
188 square miles, is regulated by Chester Morse Lake, with
an active storage of 40,000 acre-feet; the Cedar River is
primarily used for water supply, recreation and fisheries,
and to prevent saltwater intrusion into Lake Washington at
the Chittendon Locks. The Sammamish River is about 14 miles
long and drains about 196 square miles; it is primarily used
for fisheries and recreation. Numerous smaller streams within
the study area provide inflow to the larger lakes and rivers,
and serve as important fishery and recreational resources.
The quality of study area surface waters is generally
good. Metro has rated lakes, rivers, and streams for beneficial
uses based on its ongoing water quality monitoring programs.
Table 3-2 presents a summary of Metro's lake use ratings,
and Table 3-3 presents a summary of Metro's river and small
streams use ratings.
Water quality of the Green-Duwamish River is of special
importance for this EIS because it is the present discharge
location for Renton treatment plant effluent, and because
some long-term alternatives for the Renton plant involve
continued river discharge. Details regarding water quality
within the Green-Duwamish River are presented in Chapter 5
of the EIS.
Puget Sound
Puget Sound is a semiertclosed water body where sea water
from the open ocean mixes with fresh waters from rivers and
lakes draining the sound. The sound consists of a series
of interconnecting deep basins separated by relatively shallow
sills. 57
-------
Ln
CO
SNOQUALME RIVER BASM
r
C CHINOOK SAL BO*
• COM0 UlLVM) tALMO*
0 CHUM
-------
Table 3-2. Lake Use Ratings
Fishability
Lake
Large Lakes
Sammamish
Washington
Small Lakes
Bass
Beaver
Cottage
Deep
Desire
Dolloff
Kathleen
Lucerne
Meridian
Moneysmith
Morton
Number Twelve
Panther
Phantom
Pine
Pipe
Retreat
Sawyer
Shadow
Shady
Spring/Otter
Wilderness
Aesthetics
Fair
Good
Fair
Good
Poor
Good
Poor
Poor
Fair
Good
Good
Poor
Fair
Fair
Poor
Fair
Fair
Good
Good
Fair
Good
Fair
Fair
Fair
Trout Spiny Ray
Habitat Habitat
Good
Good
Good
Good
Insufficient Data
Good
Fair
Good
Fair
Good
Fair
Good
Fair
Insufficient Data
Fair
Fair
Insufficient Data
Fair
Insufficient
--
Good
Insufficient
Insufficient
Good
Fair
Fair
Good
Good
Fair
Fair
Fair
Good
Data
Fair
Good
Data
Data
Good
Good
Good
Good
Good
Good
Fair
Fair
Swimmability
Good
Good
Fair
Fair
Fair
Good
Poor
Poor
Fair
Good
Good
Poor
Fair
Fair
Poor
Insufficient
Data
Poor
Good
Good
Fair
Fair
Fair
Good
Good
SOURCE: Metro, 1979e.
59
-------
T.ibU- j-i. River and Sm,i [ 1 SLruam U:;u Hatinys
River /Stream Station
Rivers
Upper Green
Lower Green
Duwamish
Cedar
Sammaraish
Small Streams
Mill Creek
Spring Brook
McAleer Creek
Fairweather Creek
Tibbetts Creek
Issaquah Creek
North Fork
East Fork
Mason Creek
Holder Creek
Carey Creek
15-Mile Creek
Soos Creek
Covington Creek
Jenkins Creek
Little Soos Creek
West Branch
Swamp Creek
North Creek
Little Bear Creek
Bear-Evans Creek
Coal Creek (Green River)
Longfellow Creek
Coal Creek (Lake Washington)
Juanita Creek
Thornton Creek
Forbes Creek
Yarrow Bay
Lyon Creek
Newaukum Creek
Deep Creek
May Creek
Kcisey Creek
Crisp Creek
B319
A319
315
311
3106
309
307
305
H438
A438
0438
0486
0480
0450
A315
E315
0317
E317
H317
A432
E432
A499
A630
B630
U630
0631
A631
A632
0633
0634
A640
A650
A660
0320
F320
C320
D370
G320
B320
0470
B470
0474
D474
0478
B478
0484
B484
C484
G484
J484
N484
C325
C370
0442
C442
U442
0446
C446
D446
0434
K434
T434
0456
C456
0498
0430
G430
0322
F322
T322
F723
0440
K440
X440
0444
D444
0321
Fishability Hating
Good
Good
Excellent
Fair
Fair
Fair
Fair
Good
Good
Good
Good
Excellent
Excellent
Excellent
Poor
Poor
Poor
Poor
Poor
Poor
Fair
Fair
Fair
Poor
Fair
Excellent
Good
Fair
Fair
Good
Excellent
Good
Fair
Fair
Fair
Fair
Good
Fair
Fair
Fair
Good
Good
Good
Fair
Fair
Fair
Good
Fair
Good
Fair
Fair
Good
Fair
Fair
Fair
Poor
Fair
Good
Excellent
Poor
Fair
Fair
Poor
Fair
Fair
Poor
Fair
Good
Excellent
Good
Fair
Fair
Fair
Fair
Fair
Poor
Good
Swimmability Rating
Excellent
Good
Poor
Poor
Poor
Fair
Poor
Poor
Excellent
Good
Fair
Good
Fair
Poor
Poor
Poor
Poor
Poor
Poor
Poor
Good
Excellent
Fair
Poor
Excellent
Fair
Fair
Good
Good
Poor
Good
Excellent
Excellent
Good
Good
Excellent
Excellent
Poor
Fair
Fair
Fair
Poor
Fair
Fair
Poor
Poor
Fair
Poor
Poor
Fair
Fair
Excellent
Fair
Good
Excellent
Excellent
Poor
Poor
Good
Poor
Poor
Excellent
Poor
Poor
Poor
Fair
Poor
Poor
Poor
Excellent
Excellent
Good
Fair
Fair
Poor
Fair
Excellent
SOURCE: Summarized from Metro (1980f).
60
-------
Four outfall locations are being considered in Metro's
Wastewater Management Planning for the study area: Richmond
Beach, Elliott Bay, Alki Point, and Point Pulley. All four
potential discharge locations are located in Puget Sound's
central basin, which averages about 660 feet in depth. Details
regarding water circulation at the four potential discharge
locations are presented in Chapter 5 of the EIS.
Biology
Terrestrial Biology
Figure 3-5 illustrates the main wildlife habitat types
of the study area. The great majority of nonurban and nonagri-
cultural lands, located in the eastern part of the study
area, are in evergreen, deciduous, or mixed forest. Wetland
habitats are widely dispersed throughout the study area.
Aquatic and Marine Biology
The study area is rich in freshwater aquatic habitats.
The numerous lakes and streams host a wide variety of fresh-
water and anadromous fishes, many of which are of commercial
or recreational importance. Salmon use of study area lakes
and streams is shown in Figure 3-4.
Within Puget Sound, three main habitat types can be
differentiated: intertidal (between the higher high and
the lower low tide lines), subtidal (bottom habitat below
the low tide lines), and pelagic (open water regions above
the sound's bottom). Each of these habitat types supports
representative biota.
Fisheries
The fishery resources of Puget Sound and the Lake Washington/
Green River Basins are important economically, recreationally,
culturally, and scientifically. The anadromous salmonids
occurring in the study area include all five species of Pacific
salmon (chinook, coho, red, chum, pink), searun rainbow (steel-
head) trout, cutthroat trout, and Dolly Varden char. These
species are found in Puget Sound, and, with the exception
of pink salmon, spawn in study area streams. Pacific salmon
are fished for both commercial and sport purposes, whereas
the main use of anadromous trout and char is sportfishing
only.
The fish resources of the Green/Duwamish River system are
of particular importance for this EIS. Chinook, coho and
steelhead runs of the Green River system are among the largest
in the Puget Sound region. Most of the steelhead and coho are
of hatchery origin, whereas the chinook run is the second
61
-------
-LEGEND-
FIGURE 3-3. TERRESTRIAL HABITAT OF LAKE
WASHINGTON / GREEN RIVER BASINS
-------
largest native run in Puget Sound, even though significant
numbers of chinook are also of hatchery origin. Other less
prevalent anadromous fish found in the Green River system
include cutthroat trout, Dolly Varden char, chum salmon and
pink salmon. The Muckleshoot Indian tribe propagates a
relatively small hatchery run of chum salmon (U.S. Fish and
Wildlife Service 1980).
The State Department of Fisheries has estimated the
annual value of the approximately 220,000 salmon provided
by the Green River system to sport and commercial fisheries
to be about $4 million dollars. The net economic value of
the Green River steelhead fishery is estimated to be about
$7-5 million per year (see Appendix C) .
Within Puget Sound, marine species as well as anadromous
species, are important for commercial and sportfishing. English
sole and hake are the main commercial species, and Pacific cod
and copper rockfish are the main recreational species. Shell-
fish are also important recreational and commercial species
found in Puget Sound.
Species and Habitats of Special Interest
Preservation of wetland habitats is of special concern
due to the wide diversity of fauna supported by wetlands,
and because they serve as sediment and nutrient traps. Wet-
land habitats within the study area are shown in Figure 3-5.
No plant or animal species that are permanent or regular
inhabitants of the study area have been listed by the U. S.
Fish and Wildlife Service as "threatened' or endangered.
Listed species that are occasional visitors to the study
area include the gray whale (Eschrichtius robustus), the pere-
grine falcon (Falco peregrinus), and the bald eagle (Haliaeetus
leucocephalus). EPA has determined that Metro's recommended
plan will have no .'effect on any listed threatened or endangered
species. Species and habitats of special concern within
the study area, as identified by the Washington Department
of Game, are listed in Appendix C of the EIS.
Land Use and Socio-Economics
Land Use ,
The Lake Washington/Green River Basins study area covers
approximately 620 square miles of plateaus, river valleys,
and foothills of the Puget Lowlands. Existing urban land
uses are concentrated in the western part of the study area,
with major urban concentrations along the eastern shore of
Lake Washington and in the Lower Green River Valley. Urban
land uses as of 1975 are shown in Figure 3-6.
Land use planning is the responsibility of the counties
and the cities within the study area, with planning coordina-
tion provided by PSCOG. Of particular importance in deter-
mining future land use policy within the study area are King
63
-------
•LtOIND-
FIGURE 3-6. URBAN LAND USES IN THE LAKE
WASH INGTON / GREEN RIVER BASINS, 1973
-------
County's draft General Development Guide and the communities
plans prepared by both King and Snohomish Counties for sub-
county planning areas.
Population and Housing
Historic population trends from 1930 to 1970 in King
and Snohomish Counties, and in major cities within the study
area, are shown in Table 3-4. Economic activity during World
War II provided the impetus for initial rapid population
growth in the Seattle region which, with periodic fluctuations,
has continued until today.
An estimated 202,680 households are located within the
study area, assuming an average household size of 2.65 persons.
Most multifamily dwelling units in the study area are located
within the incorporated cities. The vacancy rate in the
study area region in 1976 was 5.0 percent, according to census
bureau data; the 5 percent figure is considered to characterize;
a tight housing market.
Regional Economy and Employment
The Seattle region as a whole found its early economic
strengths in processing and shipping of lumber, fishing,
mining and agricultural products. By the early 20th century
the manufacturing and trade base of the economy was well-
established .
The region enjoyed substantial growth with the coming
of the aerospace industry in the 1940s when nonresource-
based manufacturing outpaced the traditional regional
industries. In the 1970s the region has further developed
into a service-based economy with major growth in finance,
insurance, real estate, trade, tourism, and other service
industries.
The City of Seattle still contains the major concen-
trations of manufacturing jobs in the region, although cer-
tain of the outlying communities (particularly Renton, Belle-
vue, Kirkland and Redmond) have attracted production units
and corporate offices of major manufacturers over the years.
Manufacturing employment is fairly highly concentrated:
three firms (Boeing, Weyerhaeuser and PACCAR) employ half
of the county's manufacturing labor force. This concentra-
tion has contributed to the pattern of boom and bust in the
regional economy over time. The diversification of the regional
economy - a trend of the 1960s that has continued through
the 1970s - has strengthened the region's ability to withstand
downturns in any one of its major industries.
65
-------
Year
Table 3-4. Historic Population Trends, Counties and Major Cities, 1930-1970
1930
1940
1950
1960
1970
Place
King County
Snohoraish County
Seattle
Bellevue
Mercer Island
Ren ton
Auburn
Kent
Kirkland
Redmond
Edmonds
Everett
Tacoma
Population
463,517
78,861
365,583
4,062
3,906
2,320
1,714
460
1,165
30,567
106,817
Population
504,980
88,754
368,302
4,488
4,211
2,586
2,084
530
1,288
30,224
109,408
Percent
Change
9
13
1
10
8
11
22
15
11
-1
2
Population
732,992
11,580
467,591
16,039
6,497
3,278
4,713
573
2,057
33_,849
143,673
Percent
Change
45
26
27
257
54
27
126
8
60
12
31
Population
935,014
172,199
557,087
12,809
18,453
11,933
9,017
6,025
1,426
8,016
40,304
147,979
Percent
Change
28
54
19
--
15
84
175
28
149
290
19
3
Population
1,156,633
265, 236
530,831
61,102
19,047
25,258
21,817
21,510
15,249
11,031
23,998
53,622
154,581
Percent
Change
24
54
-5
377
--
37
83
139
153
674
199
33
4
DATA FROM: U. S. Department of Commerce, Bureau of the Census.
SOURCE: Metro, 1979e.
-------
Public Services Provision
Public services within the study area are provided by
the counties, cities, and numerous special districts. The
counties are generally responsible for county roads, criminal
justice, health services, and county parks. Cities are gen-
erally responsible for providing general government, water
and sewer service, police and fire protection, parks, and
libraries within their corporate limits; in unincorporated
areas these services are the responsibility of either special
districts (for fire protection, water and sewer) or the county
Educational services are provided by special districts in
both incorporated and unincorporated areas.
67
-------
Chapter 4
DESCRIPTION OF ALTERNATIVES
Introduction
This chapter describes long-term wastewater management
alternatives for the sewer service area, and solids disposal
alternative and costs. A detailed description of Alterna-
tives A-3 and A-5 is provided, since Alternative A-3 is one
possible consequence of implementing the recommended program
described in Chapter 2 of the EIS.
Long-Term Alternatives for Sewer Service Area
Flow Projections and Service Area
The quantity of wastewater that will need to be treated
during the 20-year planning period is directly related to
the number of people in the sewer service area. Population
forecasts for the study area project that 805,000 people
will live in the study area by the year 2000 (see Chapter 6).
However, only 681,000 are projected for the sewered area.
The wastewater flow from these 681,000 people was estimated
by Metro using an average contribution of 80 gallons per
capita per day.
Also, inflow and infiltration will increase the quantity
of wastewater in the system. An extensive study of the inflow
and infiltration problem has been prepared as part of Metro's
wastewater planning (Metro, 1980d), indicating that about
1,200 gallons per acre per day would inflow into existing
sewers and that approximately 500 gallons per acre per day
would enter from new sewers.
Allowing for the domestic flow, industrial flow, and
inflow and infiltration, Metro projects that an average wet
weather flow (AWWF) of 101 MGD will occur in the year 2000.
This projection has been prepared using the forecasts based
on PSCOG's "policy" population projection (see Chapter 6),
and the flow may be greater or less depending on actual
growth rates.
The proposed sewer service area identified by Metro,
based on local land use plans and policies, is shown in
Figure 4-1. This figure identifies three types of land
69
-------
FIGURE -4-1. SERVICE AREAS
-------
within the study area: sewer service area (lands presently
authorized for sewer service by local agencies), nonsewer
area/long-term land use certain (lands which local policies
indicate should not be provided with sewer service), and
sewer service uncertain (lands where there is no clear local
policy guidance, treated as nonsewer lands for purposes of
wastewater management planning). The consistency of the
proposed service area with local land use plans and policies
is analyzed in Chapter 6 of this EIS.
Description of 15 Initial Alternatives
In its preliminary plan, Metro (1980e) presented 15
long-term alternatives for study area wastewater management.
The 15 alternatives were variations of three basic concepts:
(a) expansion of the Renton treatment plant to process all
wastewater generated in the sewer service area (example program
A), (b) expansion of the Renton plant and construction of
a plant in the Kenmore area (example program B), and (c) con-
struction of six satellite plants in addition to Renton plant
expansion and new Kenmore plant construction (example pro-
gram C). The 15 initial alternatives are summarized in
Table 4-1.
Other Long-Term Alternatives for the Sewer Service Area
Alternatives Considered and Rejected by Metro. Other
alternatives for meeting the long-term needs of wastewater
management were considered and rejected by Metro early in
the planning process. These include large-scale decentralized
facilities, land application of Renton and Kenmore effluent,
wasteload reductions, in-river actions, and alternative treat-
ment plant layouts. These alternatives were considered by
Metro to be incapable of meeting all the needs of a long-
term project. The following discussion presents a summary
of each of those alternatives.
Large-Scale Decentralized Facilities. Other possible
sites for large plants considered in addition to Renton and
Kenmore could be North Lake Sammamish or the Soos Creek Plateau.
Additional plants could treat wastewater generated in those
areas and discharge either to nearby bodies of water or to
land.
These plants were not pursued because of high costs.
Advanced wastewater treatment (AWT) would be required for
a discharge to water, and land acquisition would be required
for land application; both of these requirements are costly.
Also, Metro determined that the risk of pollution of Lake
71
-------
Table 4-1. Description of 15 Initial Long-Term Alternatives
Configuration
of Treatment
Alternative Plants
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Receiving Water
All treated effluent would con-
tinue to be discharged to the
Green/Duwamish River.
All treated effluent would con-
tinue to be discharged to the
Green/Duwamish River.
All treated effluent would be
diverted via force mains and a
tunnel to the Three Tree Point
vicinity for discharge to
Puget Sound.
All treated effluent would be
diverted via a gravity sewer to
Elliott Bay for discharge to
Puget Sound.
All treated effluent would be
diverted via a gravity sewer and
tunnel to Alki Point for o_s-
charge to Puget Sound.
Level of Treatment
The level of treatment would
be increased to "advanced
secondary" with nitrification.
The level of treatment would
be increased to "advanced
wastewater treatment" with
nutrient removal.
The level of treatment would
be relaxed to "conventional
secondary" (to a 30/30 level,
i.e., 30 mg/1 BOD and 30 mg/1
SS) .
The level of treatment would
be relaxed to "conventional
secondary" (to a 30/30 levelj .
The level of treatment would be
relaxed to "conventional
secondary" (to a 30/30 level).
Total Cost
(present worth,
millions)
$267
$428
$279
$3J 9
$345
-------
Table 4-1 (cont.!
Alternative
B-l
B-2
B-3
B-4
B-5
Configuration
of Treatment
Plants
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Total Cost
(present worth,
Receiving Water
Renton effluent would con-
tinue to be discharged to
the Green/Duwamish River.
Kenmore effluent would be
diverted via a tunnel to
Richmond Beach for discharge
to Puget Sound.
Renton effluent would continue
to be discharged to the Green/
Duwamish River.
Kenmore effluent would be
diverted via a tunnel to Richmond
Beach for discharge to Puget
Sound.
Renton effluent would be diverted
via force mains and a tunnel to
the Three Tree Point vicinity for
discharge to Puget Sound .
Kenmore effluent would be diverted
via a tunnel to Richmond Beach
for discharge to Puget Sound.
Renton effluent would be diverted
via a gravity sewer to Elliott Bay
for di<=charc;e to Puget Sound.
Kenmore effluent would be diverted
via a tunnel to Richmond Beach for
discharge to Puget Sound.
Renton effluent would be diverted
via a gravity sewer and tunnel to
Alki Point for discharge to Puget
Sound.
Kenmore effluent would be diverted
via a tunnel to Richmond Beach for
discharge to Puget Sound.
Level of Treatment millions)
At Renton the level of treat-
ment would be increased to
"advanced secondary" with
nitrification.
At Kenmore the level of treat-
ment would be "conventional
secondary" (to a 30/30 level).
At Renton the level of treatment
would be increased to "advanced
wastewater treatment" with
nutrient removal.
At Kenmore the level of treatment
would be "conventional secondary"
(to a 30/30 level) .
At both Renton and Kenmore the
level of treatment would be
"conventional secondary"
(to a 30/30 level) .
At both Renton and Kenmore the
level of treatment would be
"conventional secondary"
(to a 30/30 level) .
At both Renton and Kenmore the
level of treatment would be
"conventional secondary"
(to a 30/30 level) .
$329
$469
$345
$397
$423
-------
Table 4-1 (cont.)
Configuration
of Treatment
Alternative Plant
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Receiving Water
Renton effluent would continue
to be discharged to the Green/
Duwamish River. Kenmore effluent
would be diverted via a tunnel to
Richmond Beach for discharge to
Puget Sound. Effluent from the
six decentralized plants would be
stored during the wet season and
used for "nonfood" crop irrigation
during summer months on lands
owned (or controlled) by Metro.
Renton effluent would continue
to be discharged to the Green/
Duwamish River. Kenmore effluent
would be diverted via a tunnel to
Richmond Beach for discharge to
Puget Sound. Effluent from the
six decentralized plants would be
stored during the wet season and
used for "nonfood" crop irrigation
during summer months on lands
owned (or controlled) by Metro.
Renton effluent would be diverted
via force mains and a tunnel to the
Three Tree Point vicinity for dis-
charge to Puget Sound. Kenmore
effluent would be diverted via a
tunnel to Richmond Beach for dis-
charge to Puget Sound. Effluent
from the 6 decentralized plants would
be stored during the wet season and
used for "nonfood" crop irrigation
during summer months on lands owned
(or controlled) by Metro.
Renton effluent would be diverted
via a gravity sewer to Elliott Bay
for discharge to Puget Sound.
Kenmore effluent would be diverted
via a tunnel to Richmond Beach for
discharge to Puget Sound. Effluent
from the six decentralized plants
would be stored during the wet season
Total Cost
(present worth,
Level of Treatment millions)
At Renton the level of treatment
would be increased to "advanced
secondary" with nitrification.
At Kenmore the level of treatment
would be "conventional secondary"
(to a 30/30 level) . At the six
decentralized plants the level
of treatment would be "conventional
secondary" .
At Renton the level of treatment
would be increased to ''advanced
wastewater treatment" with nutrient
removal. At Kenmore the level of
treatment would be "conventional
secondary" (to a 30/30 level). At
the six decentralized plants the
level of treatment would be "con-
ventional secondary".
At Renton, Kenmore and the six
decentralized plants the level of
treatment would be "conventional
secondary" (to a 30/30 level) .
At Renton, Kenmore and the six
decentralized plants the level of
treatment would be "conventional
secondary" (to a 30/30 level) .
$359
?499
$386
$426
and used for "nonfood" crop irrigation
during summer months on land owned
4or control 1 rd) by Metro.
-------
Table 4-1 (cont.)
Alternative
C-5
Configuration
of Treatment
Plants
Receiving Water
Renton effluent would be diverted
via a gravity sewer and tunnel to
Alki Point for discharge to Puget
Sound. Kenmore effluent would be
diverted via a tunnel to Richmond
Beach for discharge to Puget Sound.
Effluent from the six decentralized
plants would be stored during the
wet season and used for "nonfood"
crop irrigation during summer months
on lands owned (or controlled) by
Metro.
Level of Treatment
At Renton, Kenmore and the six
decentralized plants the level
of treatment would be "conven-
tional secondary" (to a 30/30
level).
Total Cost
(present worth,
millions)
5453
SOURCE: Metro, 1980g.
-------
Sammamish was too great from a nutrient contamination stand-
point. Overall, it was determined that the transportation
of those wastes to other areas is more cost-effective than
local treatment and disposal.
Large-Scale Land Application. Metro's facilities plan
consultant has prepared a detailed assessment of land treat-
ment alternatives for Renton effluent (Brown and Caldwell,
1981). This assessment considers slow rate and rapid in-
filtration land treatment of Renton effluent. Winter storage
of effluent would be required under slow rate application,
but not under rapid infiltration.
It is estimated that for slow rate application, about
12,600 acres of land would be needed to treat a year 2000
average wet weather flow (AWWF) of 72 MGD, and that 16,000
acres would be needed to treat a year 2000 AWWF of 99 MGD.
Rapid infiltration, by comparison, could be accomplished
with about 1,200 acres of land for infiltration ponds and
a buffer zone, assuming a year 2000 AWWF of 99 MGD.
Costs of the land application alternatives are con-
siderably higher than transfer of Renton effluent to Puget
Sound under Alternative A-3. The cost of slow rate land
application is estimated to be $2,860 per million gallons
(MG), and the cost of rapid infiltration is estimated to
be $1,130 per MG; this compares to a cost of $570 per MG
for Alternative A-3. Other disadvantages of land application
alternatives noted by Brown and Caldwell are that they would
provide capacity only to the year 2000, whereas the Renton
tunnel/outfall would have capacity to serve approximately
year 2030 flows; that sufficient quantities of suitable land
may not be available; and that concerns exist regarding ground-
water contamination and public resistance.
h/asteload and Flow Reductions, Wasteloads and flows
to the Renton plant could be reduced by controlling infil-
tration/inflow (I/I) or reducing domestic or commercial/
industrial inflows. This would reduce total wastewater flows,
though pollutant loadings would remain the same. I/I offers
the greatest potential for reduction of total flow in the
Renton tributary system. For both the Renton and West Point
systems, as much as 36 percent of the annual flow is due
to I/I (Metro, 1980d). Although a potential of 29.5 MGD
could be eliminated through correction of I/I problems,
analysis by Metro showed that the cost of treating this flow
is less than the cost of correcting I/I problems.
Potential treatment plant flow reduction measures identified
by Metro are shown in Table 4-2. Reduction of other flows
by retrofitting homes with watersaving features and appliances,
and requiring them in all new construction, could achieve
76
-------
Table 4-2. Potential Treatment Plant
Flow Reduction Measures
Flow reduction
measures
1. Domestic
watersaving
devices
a. Existing homes
b. New homes
Rate structure
Public education
program
2 . Industrial
pretreatment
Action
required
Public education.
increase water
costs
Change building
codes
Increase water
use costs over
base rate
Purveyor action
Implement
pretreatment
program
Responsible
agency3
Water
purveyor
City,
counties
Water
purveyor
Water
purveyor
Metro
Nastewater reduction,
percent
Within
category
16
39
minimal
minimal
Total
flow
W
6b
h
6C
minimal
minimal
Reduction will be in
pollutant load, not
flow
List of water purveyors follows in Table 02-3.
Percentage of total flow reduction, year 2000
Year 1980: existing—8 percent, new homes — 0 percent
Year 1990: existing—6 percent, hew homea--4 percent
Year 2000: existing—6 percent, new homes--6 percent
Ajfiunes approxina te ly 40 percent of existing non-«ewer homes will
b« sewered by 2000.
SOURCE: Metro, 1980h.
77
-------
a 12 percent reduction in flow by the year 2000. Also,
industrial wasteloads to the plant could be reduced; control
of heavy metals from industrial sources is being studied
by Metro in its toxicant pretreatment planning study.
Satellite Pretreatment. This is similar to Alternative C
except that the effluent would be discharged to the Metro
system. Metro analysis of this alternative indicates that
the benefits do not appear to justify the cost.
In-River Actions. In-river actions were considered
to reduce impacts of the Renton plant effluent. The alter-
natives considered were: (1) wet season retention at Howard
Hansom Dam and dry season release, (2) in-river aeration,
(3) chemical treatment, and (4) bank shading. These alterna-
tives are considered by Metro to either be unrealistic (in
the case of wet season retention) or ineffective as a long-
term solution.
Alternative Treatment Plant Layouts. Several other
possible layouts were considered by Metro but were not
accepted for unspecified engineering and operational reasons.
Wastewater Reuse Alternatives. A portion of the Renton
plant effluent could be reused for a variety of purposes,
such as crop irrigation, landscape or golf course irrigation,
industrial process water, industrial cooling water, or ground-
water recharge. Wastewater reuse can reduce effluent waste-
loads to receiving waters, at the same time augmenting existing
freshwater supplies. In other more water-short parts of
the country, wastewater reuse projects are being successfully
implemented, and are encouraged by the higher level of EPA
funding for innovative/alternative projects.
It has been pointed out by Metro (1980h) that demand
for alternative sources of water in the Seattle area appears
to be low. As growth in population and water demand continue,
however, the market for reclaimed wastewater could improve.
In fact, as discussed in Chapter 6, an additional source
of water supply will be needed for the Seattle region in
the not too distant future (Seattle Water Department, 1980).
Development of this source will increase the future costs
of freshwater supplies, making reclaimed wastewater more
economically viable than at present.
The No-Project Alternative. EPA procedures for imple-
menting NEPA require that the impacts of a no-project alter-
native be examined in EISs. Under a no-project alternative,
no new facilities would be constructed. Treatment capacity
at the Renton plant would not be expanded. Discharge of
the Renton plant effluent would continue to the Duwamish
River. Solids would continue to be pumped to the West Point
plant.
-------
Under the no-project alternative, population growth
within the study area would still be likely to continue,
creating problems for Metro's wastewater facilities. The
pump stations that are not already overloaded would be eventually
inundated by excess flow, with resultant overflow of the
pump stations or backup in the interceptors until they over-
flow. The flow that did reach the plant would increasingly
exceed the plant's capacity to completely treat it. Use
of chemicals would increase in an effort to compensate for
the high flows. But, over the long term, flow would increase
until any "nonstructural" method of increasing the plant's
treatment capability would be exceeded. Consequently, partially
treated effluent would be discharged to the river, and Metro
would be in violation of its discharge permit. Continued
permit violations could result in daily fines or a sewer
moratorium within the Renton plant service area.
If none of the facilities discussed in the facilities
plan is constructed, current users would continue to pay
the monthly charge of $4.50; this cost would be likely to
escalate over time as Metro's O&M costs escalate. The biggest
''cost" of a no-project alternative is the unquantifiable
environmental cost which would result from decreased water
quality in the Green/Duwamish River.
A second type of no-project alternative would be no
action as to EPA funding of Metro's recommended program.
If no grant funds were provided, the recommended program
would become less financially feasible, but some action would
probably be taken, resulting in higher local costs.
Description of Screening/Selection Process
and Final Alternatives
The Selection Process
Metro's selection of alternatives for final consideration
was accomplished by a three-stage screening procedure. The
first stage in the selection process compared the attributes
of each alternative to baseline criteria. The baseline
criteria were water quality, cost and land use. The water
quality standards consisted of Department of Ecology (DOE)
receiving water standards (the Duwamish River is a Class A
stream at the point of discharge); the DOE "nondegradation
policy"; and the DOE "Lake Washington policy" (no discharge
to Lake Washington). Other water quality criteria used as a
baseline were the NPDES permits in effect and the EPA
secondary treatment effluent limitations for surface water
79
-------
(30 mg/1 BOD, 30 mg/1 suspended solids). The baseline cost
criterion was an EPA threshold for "high cost projects";
for King and Snohomish Counties the threshold is a monthly
cost of $40. The baseline land use criterion was compati-
bility and consistency with applicable municipal and county
land use plans and policies.
All 15 alternatives were acceptable when compared to
the baseline criteria. The alternative which survived the
first stage screening and which had the lowest project pre-
sent worth cost is Alternative A-l," it is termed the accept-
able least cost alternative (ALCA).
The second stage screening was used to determine how
well the ALCA and the other alternatives met a more detailed
set of benchmark criteria. The ALCA became a benchmark
for comparison to the other alternatives. Table 4-3 displays
Metro's rating of the 15 initial alternatives against 25
detailed water quality, cost, land use, and other benchmark
criteria; these ratings are explained in the Draft Wastewater
Management Plan.
The third and final stage of the screening/selection
process evaluated alternatives which survived the second
screening process; these "final" alternatives had possible
overriding benefits justifying further detailed analysis
in wastewater management planning. Three alternatives were
considered to have possible overriding benefits. These
alternatives, plus the ALCA, consist of: Alternative A-l
(the ALCA), Alternative A-3 (centralized treatment, dis-
charge at Point Pulley), Alternative A-5 (centralized treat-
ment, discharge at Alki Point), and Alternative B-l (dual
treatment centers, Renton discharge to the Green/Duwamish
River) .
Expanded Description of Final Alternatives
Alternative A-l. With Alternative A-l, the Renton treat-
ment plant would treat the combined flows of the entire service
area, except the Swamp Creek drainage, which would continue
to be served by the West Point treatment plant. Discharge
of Renton plant effluent would continue to the Green/Duwamish
River. Alternative A-l is illustrated in Figure 4-2.
Under this alternative, the Renton plant would be expanded
to 99 mgd capacity to treat projected 20-year flows. This
requires expansion of the existing 72 MGD primary treatment
facilities by 27 MGD using the existing treatment scheme
and expansion of the activated sludge secondary system by
63 MGD. Expansion of the activated sludge process would
-------
Table 4-3. Metro Rating of Initial Alternatives Against
the ALGA to Identify Potential Overriding Benefits
Evaluation criteria
Water Quality Criteria
DOE water quality
standards
NPDES permit require-
ments
EPA effluent limita-
tions
EPA/DSHS drinking
water standards
Fisher ies/ shellfish
protection
Reliability
Receiving water
sensitivity
Consistency with 208
Cost Criteria
Monetary costs:
Present worth
Capital
OiM
Energy/chemical costs:
Electrical energy
Chemical
Labor staff costs
Reuse potential
EPA/DOE financing
Impact of inflation
User rates
Cost-sharing potential
Discount rate
Planning period
Land Use Criteria
Compatibility
Flexibility and staged
construction
Site impacts
Site acquisition
Other Criteria
Public input
Environmental
Compatibility with
Puget Sound plans
Alternative
A2
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KEY: + Advantage compared with ALCA
Disadvantage compared with ALCA
- No net advantage/disadvantage
SOURCE: Metro, 1980g.
-------
FiouRE -»-2. ALTERNATIVE A-1
-------
include additional equipment and process modifications to
provide nitrification. The current design of the Renton
treatment plant lends itself to increases in capacity by
increments of 18 mgd to keep the plant in hydraulic balance.
Nine mgd increments may be used, but operationally the balance
is considered by Metro to be more difficult.
All solids captured at the Renton plant would be treated
at the Renton treatment plant site, and solids would no longer
be pumped to the West Point plant. Proposed solids handling
facilities include gravity thickening for primary sludge,
air flotation thickening for waste-activated sludge, and
anaerobic digestion stabilization, followed by belt or
filter press dewatering. The dewatered solids would be
transported to final land disposal/reuse sites; the status
of Metro's long-term solids management planning is discussed
later in this chapter. Methane gas produced during anaerobic
digestion would be utilized at the plant by gas engines,
either directly driving process units or electrical generators.
Collection system modifications would be required for
Alternative A-l. Construction of the Redmond connection
and the North Creek/Hollywood connection would be required
to route North Lake Sammamish and North Lake Washington flows
to the Renton plant; these areas are currently served by
Metro's West Point plant. The Redmond connection includes
two pumping stations and force mains capable of transporting
an ultimate capacity of 75 MGD. The North Creek/Hollywood
connection consists of one pumping station and about 24,000
feet of interceptor piping.
The construction is proposed to take place in two
phases. The first phase would bring the Renton treatment
plant capacity up to 72 MGD, including solids handling, by
1985. The second phase would increase the plant capacity
to 99 MGD by 1990. The Redmond connection would be com-
pleted by 1984, and the North Creek/Hollywood connection
would be constructed concurrently with the second expansion
of the plant. Those facilities that cannot easily be staged
(e.g., tunnels and gravity sewers) would be sized for an
ultimate planning period of 50 years.
The Phase 1 capital program is estimated to cost $164.1
million, of which $145.3 million is for plant expansion and
$18.8 million for implementing service area changes. The
Phase 2 capital program is estimated to cost $98.1 million,
of which $77.9 million is for plant expansion and $20.2 million
is for service area modification. The annual O&M cost, averaged
over the planning period, is $12.6 million. The project's
present worth is $267 million.
83
-------
The impact on user rates is a function of the project
costs, the level of grant support, and annual costs of O&M.
If no grant funds were available the rate increase due to
Alternative A-l would be $5.40 per month; with 50 percent
grant funding it would be $3.50 per month; and with 75 percent
grant funding it would be $2.50 per month.
It is expected that about 98,000,000 Kwh per year will
be required to treat the 99 MGD under Alternative A-l; this
translates to about 2,710 Kwh per million gallons. Annual
tons of chemicals used for Alternative A-l can be anticipated
to be 760 tons per year of chlorine, 240 tons per year of
sulfur dioxide and 4.3 tons per year of ferric chloride.
Alternative A-3. Alternative A-3, like Alternative A-l,
is a centralized treatment scheme. However, Alternative A-3
calls for discharge of treated effluent to Puget Sound in the
Point Pulley area. The marine discharge allows a reduced
level of treatment. The advanced secondary treatment of
Alternative A-l may be reduced to a basic secondary treatment
scheme, as defined by EPA requirements (i.e., 30 mg/1 BOD
and 30 mg/1 SS). Alternative A-3 is illustrated in Figure 4-3.
This alternative calls for treating an incoming liquid
stream of 99 MGD to meet the 30/30 effluent requirements.
Because the degree of treatment is less, the capacity rating
on the existing secondary treatment elements may be uprated,
thus reducing the size of additional needed facilities.
Effluent from the Renton plant would be discharged through
a tunnel into the marine waters of Puget Sound in the vicinity
of Three Tree Point.
All solids collected at the Renton plant would be treated
on the Renton treatment plant site, using the same sludge
handling facilities as Alternative A-l. Since the amount
of solids will be less than with Alternative A-l, the sludge
treatment units may be downsized accordingly.
The collection system modifications proposed for Alter-
native A-3 are the same as those for Alternative A-l, the
Redmond connection and the North Creek/Hollywood connection.
Project staging for Alternative A-3 is in two phases.
Phase 1 calls for expansion of the treatment plant capacity
to 72 MGD, with construction completed by 1985. Phase 2
would add 27 MGD capacity, with construction completed by
1990. Collection system modifications would be staged and
sized as in Alternative A-l.
84
-------
t I 1 I 4
-LEGEND-
ftCttTOM tOOO MMVICI AHA
TfttATHMT W.ABT
PUMP STATION
— SERVICE AMA
••— CFTLUIMT OOTFAU.
ALTERNATIVES A-3 6. A-O (PREFERRED PROGRAM)
-------
The Phase 1 capital program is estimated to cost $233.8
million, of which $74.8 million is for plant expansion, $140.2
million for the effluent outfall, and $18.8 million for service
area changes. The Phase 2 capital program is estimated to
cost $76.0 million, of which $55.8 million is for the plant
expansion, and $20.2 million is for additional service area
changes. The annual O&M cost, averaged over the planning
period, is $8.9 million. The projects's present worth is
$279 million.
The impact on user rates is a function of the project
costs, the level of grant support, and annual O&M cost.
If no grant funds are available the rate increase due to
Alternative A-3 would be $5.50 per month; with 50 percent
grant funding the rate increase would be $3.20 per month;
and with 75 percent grant funding it would be $2.10 per month.
It is expected that about 87,000 Kwh per year will be
needed to treat the 99 MGD using Alternative A-3; this trans-
lates to about 2,410 Kwh per million gallons. Annual tons
of chemicals used for Alternative A-3 can be anticipated
to be 760 tons per year of chlorine and 3.9 tons per year
of ferric chloride.
Alternative A-5. Alternative A-5 is identical in all
respects to Alternative A-3, with the exception that plant
effluent is transmitted to Alki Point/Duwamish Head for dis-
charge to Puget Sound (see Figure 4-3). Effluent from the
Renton plant would be discharged via conventional conduit
and tunnel to marine water off Alki Point.
The Phase 1 capital program is estimated to cost $318.5
million, of which $74.8 million is for plant expansion, $224.9
million is for the effluent outfall, and $18.8 million is
for service area changes. The Phase 2 capital program is
estimated to cost $76.0 million, of which $55.8 million is
for further plant expansion, and $20.2 million is for additional
service area changes. The annual O&M cost, averaged over
the planning period, is $9.3 million. The project's present
worth is $345.0 million.
The impact on user rates is a function of the project
costs, the level of grant support, and annual O&M cost. If
no grant funds are available the rate increase due to
Alternative A-5 would be $7.00 per month; with 50 percent
grant funding, the rate would $4.00 per month; and with 75
percent grant funding, it would be $2.50 per month.
86
-------
It is expected that about 89,000,000 Kwh per year will
be needed to treat the 99 MGD using Alternative A-5; this
translates to about 2,460 Kwh per million gallons. Annual
tons of chemicals used in Alternative A-5 can be antici-
pated to be 760 tons per year of chlorine and 3.9 tons per
year of ferric chloride.
Alternative B-l. Alternative B-l is a dual treatment
center alternative whereby the Renton plant would continue
to serve the existing Renton service area and a new Kenmore
treatment plant would serve the north part of the study area
currently tributary to West Point. Under Alternative B-l,
Renton treatment plant would be expanded to 72 MGD. The level
of treatment would also be upgraded to an advanced secondary
system with nitrification. Alternative B-l is illustrated in
Figure 4-4 . '
Under Alternative B-l a new 27 MGD treatment plant would
be constructed in the Kenmore vicinity. The plant's treatment
processes would be similar to those of the existing Renton
plant. It would utilize conventional primary sedimentation
followed by an activated sludge secondary system, clarification
chlorination and dechlorination. The Kenmore plant would
be designed and operated to produce a 30/30 effluent (30
mg/1 each of BOD and SS).
Solids handling processes for the 72 MGD Renton facility
would be identical to Alternatives A-l, A-3, and A-5. The
Renton plant, with its upgraded treatment, would discharge
directly to the Green/Duwamish River. The Kenmore plant
would require construction of a tunnel and outfall to Richmond
Beach for discharge to Puget Sound.
Alternative B-l does not require the construction of
either the Redmond connection or the North Creek/Hollywood
interceptor. No major collection system modifications are
required for this option.
The staging for Alternative B-l is also in two phases.
Phase 1 calls for expansion of the Renton plant, construction
of Renton plant solids handling facilities, and construction
of 18 MGD capacity at the Kenmore plant, together with the
tunnel and outfall for effluent disposal. All of the Phase 1
construction would be completed by 1985. Phase 2 construction,
to be completed by 1990, calls for expansion of the Kenmore
plant to 27 MGD.
87
-------
FIGURE <»-4. ALTERNATIVE B-1
-------
The Phase 1 capital program is estimated to cost $294.8
million, of which $145.3 million is for the Renton plant,
$51.3 million is for the Kenmore plant, and $98.2 million
is for the Kenmore plant outfall to Richmond Beach. The
Phase 2 capital program is estimated to cost $27.8 million
for expansion of the Kenmore plant. The annual O&M cost,
averaged over the planning period, is $11.4 million. The
project's present worth is $329.0 million.
The impact on user rates is a function of the project
costs, the level of grant support, and annual O&M cost. If
no grant funds are available the rate increase due to
Alternative B-l would be $6.10 per month; with 50 percent
funding, the rate increase would be $3.70 per month; and
with 75 percent grant funds, it would be $2.60 per month.
It is expected that about 75,000,000 Kwh per year will
be needed to treat the 99 MGD using Alternative B-l; this
translates to about 2,080 Kwh per million gallons. Annual
tons of chemicals used for Alternative B-l can be anticipated
to be 550 tons per year of chlorine, 170 tons per year of
sulfur dioxide, and 3.8 tons per year of ferric chloride.
Collection System Changes
The Redmond connection and the North Creek/Hollywood
connection are the primary changes in the collection system.
Both include gravity sewers, pump stations, and force mains.
Metro selected a 50-year staging period as most cost-effective
for sizing gravity sewers, pump station structures, and purchase
of land and rights-of-way. All other parts of the collection
system are sized for 20 years.
The Redmond connection includes two pumping stations,
the York station, with an ultimate capacity of 75 MGD and
three force mains, and the Totem Lake station, with an ultimate
capacity of 75 MGD with twin force mains. Costs and phasing
of the Redmond connection are shown in Table 4-4. Previous
Metro studies (Metro, 1978g) have identified the preferred
route alignment, and Metro is currently securing needed rights-
of-way. Metro projects that the Redmond connection should
be ready for detailed design in 1981.
The North Creek/Hollywood connection would not be on-
line until 1993. The North Creek/Hollywood connection would
have an ultimate capacity of 37 MGD, and would include con-
struction of one new pump station, the Woodinville station.
Costs and phasing for this project are shown in Table 4-4.
Metro has deferred detailed staging and alignment decisions
for the North Creek/Hollywood connection until planning for
Phase 2 is initiated.
89
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Table 4-4. Costs for Redmond Connection and
North Creek/Hollywood Connection -
Alternatives A-3/A-5
Facility
Redmond Connection, 75 mgd
North Lake Sammamish
interceptor
York pump station
Phase 1, 30 mgd
Phase 2, 75 mgd '
Totem Lake interceptor
Totem Lake pump station
Phase 1, 30 mgd
Phase 2, 75 mgd
Redmond interceptor
extension
Other costs
Subtotal
Engineering, taxes,
contingencies at
40 percent
Redmond Connection, total
project cost
Item
108-in. RCP
Station
30-in. force
main
Pumps
30-in. force
main
84-in. RCP
Station
36-in. force
main
Pump
36-in. force
main
54-in. RCP
Quantity
2,600 ft
3 pumps at
15 mgd
2 at 1,400 ft
3 at 15 mgd
1 at 1,400 ft
4,100 ft
3 pumps at
15 mgd
1 at 3,100 ft
3 at 15 mgd
1 at 3,100 ft
1,300 ft
Estimated cost,
million dollars3
Phase 1
2.34
3.40
0.26
2.26
3.40
0.44
0.39
0.63
13. 43
5.37
18. 80
Phase 2
0.30
0.10
0.30
0.37
1.07
0.43
1.50
90
-------
Table 4-4. Cont'd.
Facility
North Creek/Hollywood Connection,
37 mgd
North Creek/Woodinville
Woodinville pump station
Wood in vi lie/Hollywood
Otherb
Subtotal
Engineering, taxes,
contingency at 40 percent
North Creek/Hollywood connection,
total project cost
Annual 0&MC
Present worth
Item
60-in. RCP
54-in. kCP
New 3 7 -mgd
station
60-in. RCP
Quantity
3,700 ft
1,700 ft
1
18,500 ft
Estimated cost,
million dollars
Phase 1
0. 58
19.10
Phase 2
1.44
0.51
3.60
7.22
0.60
13. 37
5. 35
18.72
0.13
6.30
ENR-CCI 3500.
Includes special construction requirements such as utility interference, railroad,
highway, or river crossings, and land or easement purchases.
Based on mid-point of planning period.
Listed in this figure are the "firm capacities" for each of the
pump stations. Firm capacity means the capacity of the pump
station with one pump not operating and used as a reserve pump.
SOURCE: Metro, 1980g.
91
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Under the recommended program in the Final Plan, the
decision whether to construct the Redmond connection and
North Creek/Hollywood connection would be deferred. Sewered
areas currently tributary to the West Point plant may continue
to be served by that plant unless future planning decisions
call for diversion of these flows to the Renton plant.
Wastewater Treatment
The Renton plant would be expanded to treat a total
capacity of 99 MGD and to produce an effluent that contains
not more than 30 mg/1 BOD and 30 mg/1 SS. First phase_
expansion would increase the capacity of the secondary
activated sludge units from 36 to 72 MGD. Second phase
construction would increase the capacity of the entire plant
from 72 to 99 MGD. Costs for Renton treatment plant liquid
stream improvements with the preferred program are shown
in Table 4-5.
Under the recommended program in the Final Plan, the
Renton plant would be expanded to treat a total capacity
of 72 MGD. The second phase of expansion to 99 MGD would
not be needed unless flows from the West Point service areas
are diverted to the Renton plant.
Solids Handling
The proposed solids handling processes are based on
Metro's assumption that the preferred solids disposal method
will be land application. The proposed processing will utilize
gravity thickening of waste-activated sludge, anaerobic digestion
and dewatering. Methane gas is proposed to be recovered
from the anaerobic digestion process and used as a fuel for
engine-driven pumps and blowers. Other waste heat recovery
schemes are also proposed. Blend tanks are proposed as a
method of controlling odors (if raw sludge bypasses the
digesters) and equalizing the flow to the dewatering facili-
ties. Belt filters are proposed for dewatering with the
liquid filtrate recycled to the plant. The dry solids would
be trucked or railed to a disposal site. Costs for solids
handling facilities under Alternatives A-3/A-5 program are
shown in Table 4-5.
Under Alternatives A-3/A-5, solids handling processes
would be designed to handle solids from 99 MGD of effluent.
Under the recommended program in the Final Plan the solids
handling processes would be designed to handle solids from
72 MGD of effluent. The second phase of expansion to 99
MGD would not be needed unless flows from the West Point
service area are diverted to the Renton plant.
92
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Table 4-5. Costs for Renton Treatment
Plant Improvements -
Alternatives A-3/A-5
Item
Liquid Stream
Primary
Aeration
Clar if ler s
Chlonnation and
dechlorination
Subtotal
Solids Stream
Gravity thickening
DAF
Anaerobic digestion
Dewater ing
Gas recovery
Mechanical solids
handling
Subtotal
Total
Annual OiM
Present worth
Project cost, million 5
Phase 1
72 mgd
0
14.6
11.2
0 . 4
26. 2
3. 1
6. 7
22 . 7
8.4
5. 7
2. 0
48.6
74.8
Phase 2
99 mgd
19.6
11.2
8. 7
0. 3
39. 8
0.9
2. 4
7.4
2. 8
1 . 9
0.6
16.0
55.8
Total
19.6
25.8
19.9
0. 7
66. 0
4 . 0
9. 1
30. 1
11.2
7.6
2. 6
64 . 6
130. 6
6.8
135.8
b
Based on ENR-CCI = 3500, mid-1980 USWRC discount rate
7-1/8 percent.
Average over the planning period.
SOURCE: Metro, 1980g.
93
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Effluent Disposal
Six alternative routes were proposed to convey Renton
effluent to Puget Sound. The costs of each route are pre-
sented in Table 4-6 and the location of each route is illus-
trated in Figure 4-5.
The six alternative routes are summarized below
(Metro, 1981) :
"Three Tree Point/Seahurst Park. Heading west from
the Renton plant toward the Three Tree Point-Seahurst area,
three potential effluent disposal routes were selected.
Route A follows South 146th Street, Route B follows South
152nd Street, and Route C heads directly to Three Tree Point
following no street alignment. Because right-of-way acquisi-
tion is an important consideration in a project such as this,
attempts are made to follow existing public easements (i.e.,
roadways, utilities, etc.). Neither of the roadways men-
tioned is continuous and so each route would require addi-
tional purchase of right-of-way. Route C, however, would
require purchase of right-of-way along nearly its entire
length.
"All routes would cross the Green/Duwamish River, the
City of Tukwila, and would require tunnels to carry effluent
under the higher elevation areas of Riverton Heights and
Burien. Route A would have a tunnel portal in Seahurst County
Park and an outfall located off the beach there. Route B
would require purchase of land in the residential area to
the west of Lake Burien for a tunnel portal and construction
of an outfall. Route C would cross under Sea-Tac Airport
and continue to Three Tree Point with a tunnel portal and
an outfall located near the point.
"Alki Point/Duwamish Head. Logical routes for discharge
off Alki Point or Duwamish Head would follow the Duwamish
River downstream to the vicinity of Spokane Street. The
Alki Point route would then cross under a narrower width
of West Seattle through a tunnel. Three potential routes
have been selected for cost-effectiveness analysis. Route D
would follow the west side of the Duwamish, traverse West
Seattle under S.W. Hanford Street, and have an outfall jutting
northwest from Alki Point. Route E would follow the existing
sludge force mains (which transfer sludge from Renton to
West Point) on the east side of the Duwamish, then follow
East Marginal Way to South Idaho Street, and cross the river
with the existing West Duwamish Siphon. Route E would then
follow the same tunnel alignment as Route D, under SiW. Hanford
Street, finishing with an outfall due west off Alki Point.
Route F to Duwamish Head would follow the west side of the
94
-------
Table 4-6. Cost Comparison of Alternative Effluent Discharge Routes
Route
Route A:
Seahurst
Park
Route B:
Lake
Burien
Route C:
Three
Tree
Point
Route D :
West
Duwamish
Route E:
East
Duwamish
Route F:
Duwamish
Head
Item
Outfall
Tunnel
Force Main
Pump stations
Land and
easements
Outfall
Tunnel
Force main
Pump stations
Land and
easements
Outfall
Tunnel
Force main
Pump stations
Land and
easements
Outfall
Tunnel
Gravity sewer
Force main
Pump stations
Land and
easements
Outfall
Tunnel
Gravity sewer
Force main
Pump stations
Land and
easements
Outfall
Gravity sewer
Force main
Pump stations
Land and
easements
Estimated
size or
number
96 in.
120 in.
Two at 72"
Two
96 in.
120 in.
Two at 72"
Two
96 in.
120 in.
Two at 72"
Two
96 in.
120 in.
144 in.
Two at 72"
Three
96 in.
120 in.
144 in.
Two at 72"
Three
108 in.
144 in.
Two at 72"
Two
Approxi-
mate
length,
ft.
3,000
27,000
4,000
3,000
29,000
4,000
3,000
33,000
4,000
2,200
9,200
51,000
4,800
2,200
9,200
55,000
8,000
10,100
59,900
2,800
Cost, million dollars
Estimated Cost
by item
Phase 1
9.2
102.2
7.6
19.6
0.2
9.2
109.6
7.6
19.6
0.5
9.2
124.7
7.6
19.6
0.9
6.8
34.8
139.8
9.0
32.0
0.3
6.8
34.8
148.7
13.1
32.0
0.3
62.2
17-1,5
5.6
21.0
0.3
Phase 2
1.4
1.4
1.4
2.2
2.2
-—
Total
project
cost
140.2
147.9
163.4
224.9
237.9
263.6
Annual
O&M
0.6
0.6
0.6
1.0
1.0
0.92
Present
worth
110.2
115.0
128.0
176.2
186.0
206.1
Based on ENR-CCI 3500, mid-1980 costs.
TJ. S. Water Resources Council discount rate: 7 1/8 percent.
phase construction. 95
SOURCE: Metro 1981.
Present worth assumes single
-------
PUGET SOUND
SOURCE '• METRO, 1981
LEGEND
TUNNEL CONSTRUCTION
OPEN CUT CONSTRUCTION
EASEMENT REQUIRED
PUMP STATION
FIGURE 4-5. ALTERNATIVE EFFLUENT
DISCHARGE ROUTES
96
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Duwamish along Interurban Avenue Sout±i, West Marginal Way,
and 26th Avenue S.W. to Florida Street. From Florida Street
the open-cut sewer would follow Harbor Avenue to Duwamish
Head and Alki Beach Park with an outfall to the northwest."
Under Alternatives A-3/A-5, the tunnel and outfall would
be designed to convey average flows of 144 MGD and peak flows
of 325 MGD. Under the recommended program recommended in
Metro's Final Plan, this capacity would remain the same.
Solids Disposal Alternatives and Costs
The purpose of this section is to describe the alterna-
tives that Metro is currently considering for disposal of
solids generated at its various wastewater treatment plants.
Although, certain solids handling methods are being proposed
for each of the long-term Renton wastewater management alter-
natives, ultimate solids disposal is not a part of any of
the alternatives.
Metro is currently undertaking a planning study of long-
term solids disposal options. As part of this study, a pre-
liminary cost-effectiveness analysis of solids disposal options
was conducted (Metro, 1980i); the cost estimates in this
preliminary study may be modified as a result of further work.
The goal of the cost-effectiveness study was to determine the
sludge management program which would, for a 20-year planning
period, accomplish specific objectives.
The results of the cost-effectiveness study are reviewed
here to establish the relationship between the Renton treat-
ment plant solids handling facilities described earlier and
long-term solids disposal alternatives. Environmental assessment
of the long-term solids disposal alternatives will, however,
occur under a separate NEPA process.
Current Sludge Disposal Methods
Metro's sludge treatment and handling is centralized
at the West Point treatment plant. Sludge treatment pre-
sently consists of conventional anaerobic digestion to
stabilize the sludge and reduce the quantity of volatile
solids. The digested sludge is dewatered to achieve a sludge
cake that contains about 18 percent solids. The dewatered
sludge is then transported to a disposal or reuse site.
97
-------
Sludge disposal and reuse during the past 15 years have
been oriented toward examining the advantages and disadvantages
of alternative methods for disposal. The methods examined
include deepwater disposal, soil rehabilitation, crop fertili-
zation, energy recovery, and sanitary landfill disposal.
The quantity of sludge during the past 15 years has
increased. During the period 1974 through 1979 the average
dry tons produced per day ranged from 23 in 1974, to 28 in
1979, approximately a 4 percent increase per year. The recent
use of alum to improve treatment process performance has
substantially increased the volume of sludge to be treated
and continued use of alum will increase the volume of sludge
above historic rates of increase. Sludge production for
the Metro system is projected to increase from 28 dry tons
per day in 1979 to 63 dry tons per day in 1985, to 83 dry
tons per day in 2000.
Identification of Options
Eleven options were considered by Metro for sludge
utilization or disposal. The options were selected on the
basis of: (1) previous operational experience in the Puget
Sound area, or wide-scale implementation nationwide;
(2) research on utilization options conducted by Metro; and
(3) potential for energy recovery. Systemwide treatment
of sludge at the West Point and Renton facilities was assumed
for all disposal options.
Sludge treatment processes for all use or disposal options
were the same, and were identical to the treatment processes
proposed for the Renton plant as part of the Draft Wastewater
Management Plan. It was assumed that anaerobic digestion
would be the principal stabilization process. This process
was selected because it is self-sustaining and produces methane
gas for energy recovery. It was also assumed that the stabilized
sludge could be dewatered by a method that would achieve
18 percent solids before disposal, if needed.
Ocean Disposal. Under this option, digested, liquid
sludge would be barged to ocean waters off the Olympic Peninsula
which have previously beem permitted as dump sites for munitions
and ocean dredge spoils. A force main would be constructed
from the Renton plant to a new barging site located either
on the Green/Duwamish Waterway or Elliott Bay. This option
would be inconsistent with federal policies which discourage
ocean disposal of sewage sludge.
98
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Conventional Incineration. Under this option, multiple-
hearth incinerators would be installed at both the West Point
and Renton treatment plants. Dewatered, undigested sludge
would be incinerated on site, and the ash residue would be
hauled by truck for final disposal to the King County landfill.
Primary sludge at West Point would be put through clarifiers
and then dewatered; at the Renton plant, waste-activated
sludge would be thickened and then dewatered. Both would
then be fed into incinerators. Emission control equipment
would be installed to comply with air pollution requirements.
Coincineration. An alternative to conventional incineration
would be codisposal of sludge with municipal solid waste.
Although there is little operational experience in the U. S.
with this technology, coincineration has the potential for
significant energy recovery through the generation of steam.
For this option, liquid sludge from both treatment plants
would be transported by force main to a centralized handling
facility in an industrial area for dewatering and combustion,
and ash residue would be hauled by truck to the county landfill.
The low-grade steam generated by the facility would be sold
to local industrial users. Emission controls would be similar
to conventional incineration.
Sanitary Landfill. Sanitary landfilling has occasionally
been used by Metro in recent years. Under this option, digested
and dewatered sludge would be truck-hauled to the county
landfill. Landfilling could be implemented at any time;
however, the long-term (or 20-year) availability and cost
of sanitary landfilling in King County are considered highly
uncertain.
Silviculture. Metro has undertaken extensive research
on sludge application to forestlands as a soil and plant
amendment to provide additional nutrients. The tree growth
response to sludge application demonstrated by this research
indicates its potential. Two approaches are considered as
long-term options by Metro. The first involves hauling digested,
dewatered sludge from both treatment plants to a small number
of privately owned sites and application to second-growth
timber stands. Sludge would be truck-hauled from the treat-
ment plants to these sites and temporarily stored for final
application. Spray pumpers would be used for actual application.
Under the second approach, liquid sludge (4 percent solids)
would be barged to sites on the Kitsap and Olympic Peninsula
for spray application to second-growth sites in the same
manner as dewatered sludge.
99
-------
Soil Improvement. Metro has conducted a variety of
soil improvement projects. Sludge has been applied to areas
with poor soils to amend these soils to produce improved
vegetation growth. The soil improvement option involves
transporting the digested, dewatered sludge from the treatment
plants to the site by truck, and either allowing it to dry
on-site, or immediately spreading and tilling it into the
soil by plowing, and then seeding. The sludge can be mixed
with sand or sawdust at the point of application to improve
the mixing process, depending on the condition of existing
site soils. The application sites would include a portion
of land to be purchased and maintained by Metro. The sites could
be used for a variety of purposes following sludge application.
Composting. Composting digested, dewatered sludge could
provide a nonagricultural fertilizer for use in parks, road-
sides, recreation areas, and other publicly-controlled lands.
This option consists of a central facility for sludge storage,
composting, and stockpiling of the final product. Digested,
dewatered sludge would be hauled by truck to this facility,
and the composted product would be delivered by truck to
the consumers. The composting method used would consist
of large, static windrows similar to those being examined
in an ongoing University of Washington demonstration project.
Application of the compost product would be subject to regula-
tion under provisions of the Resource Conservation and Recovery
Act of 1976 (RCRA) ..
Agricultural Use. Two options were considered by Metro
for agricultural use of digested, liquid sludge. In the
first, the land required would be purchased, with possible
leasing arrangement for tenant farmers; in the second, land
use agreements would be developed with private farmers and
Metro would assume application costs. The land considered
appropriate for the agricultural application, based on agricultural
use and proximity to the treatment plants, would be located
in the Green River Valley and the Enumclaw Plateau. Sludge
would be transported by force main to storage lagoons and
then applied to the agricultural sites by tank trucks equipped
with pumps. Application would be subject to regulation under
RCRA.
Selection of A Recommended Program
The advantages, disadvantages, and costs of each
candidate program have been discussed in detail in Metro's
sludge disposal cost-effective analysis. The costs of the
options are tabulated in Table 4-7. Based on a comparison
of each option's reliability, flexibility, environmental
impact, reuse potential, public acceptance, and cost, Metro
has developed a preliminary program design with the following
elements:
100
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Table 4-7. Costs of Candidate
Sludge Disposal Systems
Candidate
System
Puget Sound Outfall
Ocean Dispersal
Conventional Incineration
Co-incineration
Sanitary Landfill
Silviculture (18%)
Silviculture (4%)
Coirposting
Soil Improvement
Agriculture w/land
Agriculture w/o land
Annual Cost Present Worth Unit Cost
($1,000) ($1,000) ($/dry ton)
6,154
8,021
12,205
15,159
9,996
9,966
8,040
9,790
11,488
18,722
13,552
69,167
90,151
137,177
170,378
112,349
112,349
90,364
110,034
129,118
210,424
152,316
280
365
554
689
454
453
366
445
524
851
616
SOURCE: Metro, 19801.
101
-------
o From 85-90 percent of Metro's sludge will be used as
a forest and plant amendment for the 20-year planning
period. The use of trucks vs. barges has not been
determined.
o A small percentage of the sludge will be used for
reclaiming marginal and poor soils. Land will be pur-
chased and leased for this purpose.
o A small percentage of Metro's sludge will be composted
sludge. The product will be made available for dis-
tribution to public agencies and commercial bulk users
for public landscaping projects.
It is estimated that the proposed project will require
from $392-$505 per dry ton of sludge depending on the final
program mix selected.
102
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Chapter 5
CONSTRUCTION AND SITE-RELATED IMPACTS OF ALTERNATIVES
Overview
Each of the lone-term wastewater management alternatives
for the Lake Washington-Green River Basins has different
components. Each of these project components will have dif-
ferent construction or site-related impacts on the environment.
Table 5-1 is a summary rating of the construction and
site-related impacts of the components making up each alter-
native; the table also lists mitigation measures for each
adverse impact. For Alternatives A-3/A-5, all the project
components are shown. For other long-term alternatives,
only the components in addition to those required for the
preferred program are listed; it should be noted that imple-
mentation of these alternatives would also eliminate the
need for construction of one or more Alternatives A-3/A-5 com-
ponents .
Table 5-1 indicates that, in general, construction and
site-related impacts associated with project components are
minor, except for certain impacts of constructing the effluent
tunnel and outfall under Alternatives A-3/A-5 or Alternative B-l
None of the impacts shown in Table 5-1 would occur if the
no-project alternative were implemented.
The remainder of the chapter expands upon construction
and site-related impacts of each alternative. The last section
is a comparative analysis of the construction employment
impacts of the long-term alternatives.
Impacts of Alternatives A-3/A-5
Alternatives A-3/A-5 include construction of the following
components: collection system changes (Redmond connection,
North Creek/Hollywood connection), Renton treatment plant
expansion, solids handling facilities, and a tunnel and out-
fall to Puget Sound.
Construction impacts of the recommended program in Metro's
final plan will be less than for Alternatives A-3/A-5 because
collection system changes would not be needed and because
the Renton treatment plant treatment processes and sludge
handling facilities could be designed to accommodate 72 MGD
103
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Table 5-1. Overview of Construction and Site-Related Impacts of Project Components
Alternatives A-3/A-5 Ala Bla
Potential incompatibility x
with adjacent land uses
Disruption of recreational
uses
Cultural resources
Traffic disruption
Visual aesthetics
Safety hazards
Noise and dust
Spoils disposal
Construction equiprrent
exhaust emissions
Soil erosion
Loss of vegetation;
wildlife disturbance
Surface water quality
and aquatic biology
impacts
Disruption of bonthic
habitat
Construction employment
3.5
X X
S -
4-1 4-14-1
C C CT1
-------
of effluent by the year 2000, rather than 99 MGD. The con-
struction impacts described below for Alternatives A-3/A-5
thus represent "worst-case" impacts that would result if
a decision is subsequently made to divert flows from the
north part of the study area to the Renton plant.
Collection System Changes
Redmond Connection.
Description of Existing Environment. The proposed Redmond
connection would be located in the vicinity of N.E. 124th
Street and a branch of the Burlington Northern Railroad system
just east of Totem Lake, King County (Figure 5-1)• Northeast
124th Street provides access from Interstate 405 to State
Route 202 and Avondale west of the Sammamish River. Land
use along the 12,500-foot-long alignment is a mixture of
industrial, commercial, transportation, agriculture (turf
and pasture), and recreation (Sammamish River). Both the
Totem Lake and York pumping stations would be located adjacent
to the Burlington Northern Railroad tracks.
Topography along a major portion of the alignment is
gently sloping, with a steep gradient between the western
branch of the Burlington Northern Railroad and 142nd Avenue
N.E. The steep portion (approximately 500 feet) is considered
an erosion hazard area by King County (Department of Planning
and Community Development (1980a).
Vegetation, for the most part, consists of herbaceous
growth (grasses, forbs) scattered patches of second-growth
(big leaf maple), and introduced species (in urban areas).
Approximately 2,300 feet of the alignment is within the 100-
year floodplain of the Sammamish River (Department of Planning
and Community Development, 1980a).
Approximately 2,600 feet of the Redmond connection (the
North Lake Sammamish interceptor and York pumping station
portion) paralleling N.E. 124th Street will be constructed
within the Sammamish Valley/Bear Creek Agricultural District
(Class II soils).
Alternative routes for the Redmond connection have not
been developed by Metro. If the decision is made to build
the Redmond connection, future environmental analyses will
consider in greater detail the impacts of the proposed route
and alternatives.
105
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SNOHOMISH COUNTY
KING COUNTY
WOODINVILLE P. S.
NORTH CREEK/HOLLYWOOD
CONNECTION
ME 145 th ST
NE 124 th ST
WOODINVILLE-
REDMOND ROAD
REDMOND
NOTE: REDMOND CONNECTION ROUTE BASED
ON PREVIOUS METRO STUDIES
NORTH CREEK /HOLLYWOOD ALIGNMENT
TO BE FINALIZED IN FUTURE STUDIES
^ PUMP STATION
^Bl PIPE
HI EXISTING NORTH
CREEK TRUNK
Figure 5-1. Alignment of Redmond Connection and
North Creek/Hollywood Connection
SOURCE: Metro, 1980g.
-------
Assessment of Impacts. Table 5-1 presents an overview
of construction and site-related impacts of the Redmond con-
nection and lists mitigation measures for adverse impacts.
Virtually all features of the Redmond connection (pump stations,
gravity pipes and force mains) will lie adjacent to existing
transportation corridors (N.E. 116th Street, N.E. 124th Street
and the Burlington Northern Railroad), and will be compatible
with existing land uses and inning. Easements will be required
through or adjacent to 31 parcels. Some fill will be required
in the vicinity of the York pumping station, near Slater
Avenue N.E. (N.E. 124th Street) and at the Totem Lake pumping
station.
The impact on cultural resources is uncertain at this
time. Portions of the alignment (specifically the North
Lake Sammamish Interceptor) will lie within an area of high
potential for archeological resources. However, much of
the alignment has been greatly disturbed by previous con-
struction activities. Once the precise alignment is known
an archeological survey will be conducted.
According to the King County sensitive areas map folio
(1980), portions of the alignment will be within seismic
and erosion hazard areas and within the 100-year floodplain
of the Sammamish River. Furthermore, construction will be
necessary within the riverbed of the Sammamish River at one
point. Special construction techniques would be necessary
to prevent erosion problems on the steep slopes and major
impacts on water quality and streambed conditions within
the Sammamish River.
Construction of a portion of the York force mains may
require removal of several big-leaf maple trees at the corner
of N.E. 124th Street and Burlington Northern Railroad, and
of an unoccupied structure on the northwest corner of the
intersection.
A number of adverse impacts could be created by con-
struction of the Redmond connection. In the future, if it
is decided to build the Redmond connection, the Final EIS
for Metro's Puget Sound plants will include mitigation
measures for impacts from that construction.
North Creek/Hollywood Connection.
Description of Existing Environment. Much of the pro-
posed North Creek/Hollywood connection will traverse agricul-
tural land from Woodinville south to the existing Hollywood
pumping station at N.E. 124th Street (see Figure 5-1). Scat-
tered areas of transportation and commercial land uses occur
in Hollywood and Woodinville near State Route 522.
107
-------
Topography along the route is relatively flat, parti-
cularly from Woodinville south to the Hollywood pumping station,
Some scattered wetlands occur along the east side of the
Sammamish River, south of Woodinville (King County, 1980).
Assessment of Impacts. Table 5-1 presents an overview
of construction and site-related impacts of the North Creek/
Hollywood connection, and lists mitigation measures for adverse
impacts. The North Creek/Hollywood connection is projected
to be a Phase 2 project, and for that reason the exact align-
ment is not known at this time.
The alignment would pass through areas considered sensi-
tive by King County. Most of the alignment from Bothell
south to N.E. 124th Street would be within a Class III seismic
hazard area and the 100-year floodplain of the Sammamish
River and Bear Creek. The alignment would require one stream
crossing (Bear Creek) and construction through several wetlands
just south of Woodinville (King County, 1980).
The proposed pipeline would also traverse land within
the Sammamish Valley/Bear Creek Agricultural District and
would parallel the Sammamish River Parkway.
Special construction methods will be necessary to handle
potential seismic risks and to ensure the continued viability
of the wetland areas.
A number of adverse impacts could be created by con-
struction of the North Creek/Hollywood connection. In the
future, if it is decided to build the North Creek/Hollywood
connection, the Final EIS for Metro's Puget Sound plants
will include mitigation measures for impacts from that con-
struction .
Renton Treatment Plant Expansion
Description of Existing Environment. The Renton treat-
ment plant islocated next to the Green/Duwamish River in
a predominantly industrial area at the western edge of the
City of Renton. The site is surrounded by industrial and
railroad uses. A hill is located on the western edge of
the property. The hill constitutes a significant constraint
on the location of planned improvements to the plant.
108
-------
Figure 5-2 illustrates the Renton treatment plant layout
under the recommended program, with space shown for future
expansion under Alternatives A-3/A-5. Construction of the
proposed facilities will require fill to raise elevations
on the undeveloped part of the site from 16 feet to between
26 and 34 feet. A flood hazard analysis presented in Metro's
Companion Document indicates that the treatment plant site
will receive adequate protection from floods.
Much of the currently undeveloped area upon which new
facilities are proposed for construction has been extensively
modified due to fill activity undertaken at the time the
treatment plant was initially constructed. Soil corings
conducted as part of a cultural resources survey undertaken
for this EIS (see below) indicate that surface soils in the
undeveloped part of the site are primarily brown to grayish-
brown clayey silt. Most of the undeveloped part of the site
is vegetated with native grasses and weeds and occasional
stands of trees.
Subsurface coring at the treatment plant site was under-
taken by the University of Washington Office of Public Archeo-
logy as part of this EIS because a major archeological find
had been discovered at the immediately adjacent Earlington
Golf Course. (At the Earlington site, University of Washington
archeologists discovered a prehistoric Duwamish Indian village
thought to be between 400 and 1,000 years old.) A total
of 59 core samples was taken at the treatment plant site
to a depth of 1.8 meters; sample locations are shown in
Figure 5-3. None of the 59 cores indicated the presence
of subsurface cultural resources. In two of the cores,
occasional flecks of charcoal were noted, but these were
not considered significant. No stratigraphic bands were
observed in any of the samples, and no artifacts were
recovered.
Assessment of Impacts. Phase 1 of Alternatives A-3/A-5
calls for expansion of the Renton treatment plant to 72 MGD
by 1985; this requires construction of two additional aeration
tanks, four secondary clarifiers, and additional disinfection
facilities. Phase 2 calls for expansion of the plant to
99 MGD to serve 20-year flows; this requires the additional
construction of four primary sedimentation tanks, two aera-
tion tanks, four secondary clarifiers, and disinfection
facilities.
109
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" n nor;'™
»'»LI LJ oprJ.
I O"" DlaiSi.to ».>
LKQKND
Recommended program
"] Future expansion
SOURCE: METRO, 1981
FIGURE 5-2. RENTON TREATMENT PLANT
LAYOUT: RECOMMENDED PROGRAM
110
-------
~ ---- /
-LEGEND-
• CORE LOCATIONS
VI
TREES
SOURCE: UNIVERSITY OF WASHINGTON OFFICE OF
PUBLIC ARCHEOLOGY.
FIGURE 5-3. LOCATION OF SUBSURFACE CORINGS AT
RENTON TREATMENT PLANT SITE
111
-------
Construction and site-related impacts of treatment plant
expansion are listed and rated in Table 5-1, which also lists
mitigation measures to minimize adverse impacts. Land use
incompatibility and cultural resource impacts, although poten-
tially the most important of the site-related impacts listed
in Table 5-1, do not appear to be major concerns. Land use
incompatibility is not a major concern because industrial
or railroad uses surround the site. To the east, beyond
the drainage channel which borders the site, First City
Equities has purchased the Earlington Golf Course and is
planning to construct a manufacturing park containing ware-
houses, businesses, and offices. These uses should also
be compatible with the proposed treatment plant improvements,
provided that sufficient buffering is maintained between
the two properties.
In consultation with the State Historic Preservation
Officer (SHPO) and based on the negative results of the cultural
resource survey at the Renton treatment plant site, EPA has
determined that expansion of the treatment plant will not
affect cultural resources. However, it is possible that
cultural resources may be present in areas not sampled or
below 1.8 meters. If the ground is to be substantially dis-
turbed below 1.8 meters, and if cultural resources are noted,
then construction work will be halted and a professional
archeologist recommended by the SHPO will be consulted. Sub-
sequent SHPO recommendations will be formally considered.
These requirements will be included in an EPA grant condition.
Solids Handling Facilities
Alternatives A-3/A-5 require facilities for anaerobic
digestion, gravity thickening, dissolved air flotation, and
dewatering. Phase 1 calls for the solids handling facilities
to be designed for 72 MGD, and Phase 2 calls for expansion
to 99 MGD.
Construction and site-related impacts of the solids
handling facilities are listed and rated in Table 5-1, which
also lists mitigation measures for adverse impacts. Land
use incompatibility and cultural resource impacts are poten-
tially the most important of the impacts listed in Table 5-1.
Odors from the solids handling facilities could create conflicts
with adjacent land uses (particularly the proposed Earlington
manufacturing park), and are identified as a minor adverse
impact in Table 5-1; however, the mitigation measures of
adequate buffering and odor control technology are capable
of mitigating this impact. Cultural resources precautions
at the site have been previously reviewed.
112
-------
This EIS does not consider the site-related impacts
of ultimate disposal of sludge from the Renton treatment
plant or other Metro treatment plants. These impacts, which
are likely to be significant, will be assessed under a
separate NEPA process.
Tunnel/Outfall
The Metro Final Wastewater Management Plan defines six
alternative tunnel and outfall alignments for the disposal
of secondary effluent from the Renton treatment plant. Three
of the alternative alignments are in the vicinity of Three
Tree Point/Seahurst Park, and three are at Alki Point/Duwamish
Head approximately 9.5 miles north of Three Tree Point. The
following discussion analyzes the construction impacts of
these alternatives; water quality impacts of alternative
outfall sites are assessed in Chapter 6 of the EIS.
Description of Existing Environment.
Three Tree Point/Seahurst Park Alternatives. Figure 5-4
depicts the three proposed tunnel/outfall routes in the Three
Tree Point area. Two of the alignments, Routes A (Seahurst
Park) and B (Lake Burien), would be beneath existing road-
ways, whereas Route C (Three Tree Point) would be aligned
"cross-country", primarily beneath residential land uses.
Table 5-2 shows the land uses along each alignment.
The entire area from the Renton treatment plant to Three
Tree Point can be broadly classified as residential, with
some commercial and transportation (Sea-Tac Airport) uses.
Seahurst County Park (Ed Munro Park) is a major recreational
area located 2.5 miles north of Three Tree Point (USGS, 1979b)
Preliminary geologic information indicates that the
soil materials underlying the Three Tree Point alignments
can be classified as a mixture of gravels, soft sandstone,
shale and conglomerate; more detailed geological field work
would be conducted once the final tunnel route is selected.
Topography along the alignments varies from less than 10
feet near the treatment plant to over 400 feet near the
Seattle/Tacoma Airport and Three Tree Point
The cultural resources along the alignments are unknown
at this time. EPA has developed a grant condition requiring
Metro to ensure that a cultural resource survey is completed
by a professional archeologist prior to construction. Any
subsequent recommendations by the SHPO are to be formally
considered.
113
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PUGET SOUND
LEGEND
TUNNEL CONSTRUCTION!
OPEN CUT CONSTRUCTION
EASEMENT REQUIRED
PUMP STATION
FIGURE 5-4. ALTERNATIVE
DISCHARGE ROUTES
114
EFFLUENT
-------
Table 5-2. Existing Land Uses for Tunnel and Open-Cut Alignments
Route Alternative
Land Use
rH
0)
|
^
Residential /Mixed Urban
Roadway
Sea Tac Airport
Park Land
Conmercial
TOTAL TUNNEL LENGTH
C
0
-H
4J
W
0
u
J-l
3
V
Park Land
Indus trial /Transportation
Residential
TOTAL OPEN-CUT LENGTH
A
6,100 ft
16,000 ft
3,200 ft
1,700 ft
-
27,000 ft
2,500 ft
1,500 ft
-
4,000 ft
Three Tree Point
B C
5,500 ft 25,000 ft
19,500 ft 1,200 ft
4,000 ft 5,500 ft
-
1,300 ft
29,000 ft 33,000 ft
Same as Route A
Same as Route A
-
4,000 ft 4,000 ft
D
700 ft
7,000 ft
-
1,500 ft
-
9,200 ft
2,500 ft
51,400 fta
1,900 ft
55,800 ft
Alki Point
E
700 ft
7,000 ft
-
1,500 ft
-
9,200 ft
-
61,100 ftb
1,900 ft
63,000 ft
F
-
-
-
-
-
3,380 ft
54,040 ftc
5,280 ft
62,700 ft
TOTAL LENGTH OF ALIGNMENT
31,000 ft
33,000 ft
37,000 ft
65,000 ft
72,200 ft
62,700 ft
aRoute parallels the West Valley Highway (SR 181), West Marginal Way (Rt. 90) and the Burlington Northern Railroad.
bRoutc parallels the Burlington Northern Railroad, East Marginal Way, and Spokane Street.
CRoute parallels the Wost Valley Hi.jhway (SR 181), West Marginal Way (Rt. 99), the Burlington Northern Railroad,
Florida Street, and Harbor Avenue.
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Alki Point/Duwamish Head Alternatives. Figure 5-4 shows
the three open cut/tunnel alternative routes to Alki Point/
Duwamish Head. Routes D (West Duwamish) and E (East Duwamish)
would follow the Duwamish River toward Elliott Bay before
turning westward to Alki Point. Route F would follow the
Route D alignment from the treatment plant to just north
of S.W. Spokane Street; the alignment would continue north-
ward to Florida Street, Harbor Avenue, and then to Duwamish
Head and Alki Beach Park. The alignments would follow
existing transportation corridors along much of their
lengths. Table 5-2 depicts the land uses along each of
the alignments.
Most of the existing land use is industrial on both
sides of the Duwamish River from the Renton treatment plant
north to Spokane Street. Some mixed urban and residential
uses occur in the South Park area. Transportation corridors
parallel the river on the east (East Marginal Way) and west
(West Marginal Way) sides of the Duwamish River. Most of
West Seattle is residential, with some scattered areas of
commercial and recreational land uses. Land use along the
Route F alignment along Harbor Avenue northwest to Duwamish
Head, is residential, commercial, and recreation.
The topography and geologic conditions in the West
Seattle area are similar to those described for Three Tree
Point. Cultural resource studies have not been conducted
along the alignments, but would be prior to construction.
Geologic and Seismic Hazards. Soil instability and
seismicity risks are hazards which would be encountered along
any of the tunnel/outfall alignments. In general, surface soil
instability is associated with two potentially hazardous con-
ditions -- erosion hazards, and slide and slippage hazards.
Construction in hazardous areas could occur in the vicinity
of any of the following three areas: along the open-cut
pipeline corridors, adjacent to the tunnel portal areas,
and at the pump station site.
Based on King County's mapping of sensitive areas, the
proposed pipeline and tunnel alignments do not encounter
any designated erosion hazard areas. Slide and slippage
(landsliding) hazards, however, do occur along the proposed
alignments. King County designates potential landslide
hazards based primarily on slope inclination greater than
15 percent. In addition, the physical character of the sub-
surface material is considered.
116
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The coastal shoreline in the Three Tree Point area has
been designated by King County as a moderate-to-serious land-
slide hazard area, and similar conditions are likely to exi,st
at Alki Point as well, based on slope considerations. Therie-
fore, the design and construction of facilities in the coastal
zone, such as the proposed pump station, will have to take
landslide hazards into account. Because tunnel portals
and the pipeline adjacent to the Duwamish River could also
encounter landslide hazard areas, such facilities must be
designed and constructed with these factors in mind.
Regarding seismic risks, the entire Puget Sound basin
is classified by the U. S. Geological Survey as a Zone 3
seismic risk area indicating high seismic activity. This
classification is characterized by a history of major earth-
quake frequency and associated damage. Several earthquake
faults are known to exist within the Puget Sound area including
a recently discovered fault which runs through Alki Point.
This fault, however, is considered to have been inactive
during recent years. A meaningful seismic risk assessment
for the tunnel and outfall cannot be made until test borings
along the corridor are made during engineering predesign
of the project.
Assessment of Construction Impacts. Table 5-1 presents
an overview of construction and site-related impacts of tunnel/
outfall construction, and lists mitigation measures for adverse
impacts. Construction of the tunnel/outfall is estimated
to last for approximately 27 months; if the Seahurst Park
route is selected, Metro's engineering consultant estimates
construction activities at Seahurst Park would last about
18 months, with the full 27 months as a worst-case situation.
Different impacts will be associated with the construction
of these components of the tunnel/outfall project: force
mains or gravity lines, tunnels and pump stations.
The construction of force mains or gravity lines involves
a linear open-cut trench and generates impacts typical of
surface excavation (e.g., traffic disruption, noise, localized
effects on air quality, loss of vegetation). On the other
hand, tunneling would result in more localized construction
impacts at the tunnel entrances (portals), staging areas,
and truck routes; for this assessment, it is assumed that
a tunnel boring machine will be used for construction.
Tunneling would also create the need for spoils disposal.
Assuming the Seahurst Park route is selected, Metro estimates
that 160,000 cubic yards of spoils would be generated,
117
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assuming a 13-foot excavation diameter. Metro plans to tunnel
from east to west, and dispose of all spoils through the
east portal. However, if it becomes necessary, construction
could proceed from both ends simultaneously, and spoils could
be removed from the west portal as well.
Handling of the spoils involves the basic steps of trans-
port to the tunnel heading, transport from the tunnel heading
to the disposal site, and final disposal. Transport to the
tunnel heading would be through a "dry" method (preferred) or a
"wet" slurry pipeline method. If spoils were in slurry form, a
settling pond would be required for the approximately 20
MGD of transport water that would be generated; applicable
DOE limits on suspended solids would have to be met prior
to disposal of the settling water in either the Green/Duwamish
River (east portal) or Puget Sound (west portal). Assuming
a 1-day settling time, Metro estimates that about 3 acres
would be required for the settling pond. Because site con-
straints preclude placing a settling pond at the west portal,
in the .event spoils would be disposed from the west portal,
slurry transport of spoils could be used only if barges were
employed for settling.
Transport to the final disposal site would be by truck
from the east portal; if disposal were to also occur from
the west portal, trucks or barges could be used. Metro has
identified a number of potential spoils disposal sites, where
the spoil can be used for fill, within the vicinity of the
east portal; these include the American Can site contiguous
to the Renton plant, and the Renton plant itself, which will
require over 250,000 cubic yards of fill (more than the total
volume produced by tunnelling) to implement the recommended
program. If disposal were to occur through the west portal,
the spoils could be trucked to a final disposal site or barged
to the Tacoma industrial area. If spoils are used as fill
for construction sites as planned, impacts at these sites
from spoils disposal will be minimal.
Three Tree Point/Seahurst Park Alternatives. The three
alternative alignments (Routes A, B, and C) would require
approximately 4,000 feet of open-cut construction for force
mains, via a common route through Fort Dent Park, across
the Duwamish River and the West Valley Highway (State Route 181)
to 65th Avenue South. Each of the alternatives would require
a new effluent pump station at the Renton treatment plant
and a second pump station near each outfall location.
118
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The coastal shoreline in the Three Tree Point area has
been designated by King County as a moderate-to-serious land-
slide hazard area, and similar conditions are likely to exi,st
at Alki Point as well, based on slope considerations. Therie-
fore, the design and construction of facilities in the coastal
zone, such as the proposed pump station, will have to take
landslide hazards into account. Because tunnel portals
and the pipeline adjacent to the Duwamish River could also
encounter landslide hazard areas, such facilities must be
designed and constructed with these factors in mind.
Regarding seismic risks, the entire Puget Sound basin
is classified by the U. S. Geological Survey as a Zone 3
seismic risk area indicating high seismic activity. This
classification is characterized by a history of major earth-
quake frequency and associated damage. Several earthquake
faults are known to exist within the Puget Sound area including
a recently discovered fault which runs through Alki Point.
This fault, however, is considered to have been inactive
during recent years. A meaningful seismic risk assessment
for the tunnel and outfall cannot be made until test borings
along the corridor are made during engineering predesign
of the project.
Assessment of Construction Impacts. Table 5-1 presents
an overview of construction and site-related impacts of tunnel/
outfall construction, and lists mitigation measures for adverse
impacts. Construction of the tunnel/outfall is estimated
to last for approximately 27 months; if the Seahurst Park
route is selected, Metro's engineering consultant estimates
construction activities at Seahurst Park would last about
18 months, with the full 27 months as a worst-case situation.
Different impacts will be associated with the construction
of these components of the tunnel/outfall project: force
mains or gravity lines, tunnels and pump stations.
The construction of force mains or gravity lines involves
a linear open-cut trench and generates impacts typical of
surface excavation (e.g., traffic disruption, noise, localized
effects on air quality, loss of vegetation). On the other
hand, tunneling would result in more localized construction
impacts at the tunnel entrances (portals), staging areas,
and truck routes; for this assessment, it is assumed that
a tunnel boring machine will be used for construction.
Tunneling would also create the need for spoils disposal.
Assuming the Seahurst Park route is selected, Metro estimates
that 160,000 cubic yards of spoils would be generated,
117
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assuming a 13-foot excavation diameter. Metro plans to tunnel
from east to west, and dispose of all spoils through the
east portal. However, if it becomes necessary, construction
could proceed from both ends simultaneously, and spoils could
be removed from the west portal as well.
Handling of the spoils involves the basic steps of trans-
port to the tunnel heading, transport from the tunnel heading
to the disposal site, and final disposal. Transport to the
tunnel heading would be through a "dry" method (preferred) or a
"wet" slurry pipeline method. If spoils were in slurry form, a
settling pond would be required for the approximately 20
MGD of transport water that would be generated; applicable
DOE limits on suspended solids would have to be met prior
to disposal of the settling water in either the Green/Duwamish
River (east portal) or Puget Sound (west portal). Assuming
a 1-day settling time, Metro estimates that about 3 acres
would be required for the settling pond. Because site con-
straints preclude placing a settling pond at the west portal,
in the event spoils would be disposed from the west portal,
slurry transport of spoils could be used only if barges were
employed for settling.
Transport to the final disposal site would be by truck
from the east portal; if disposal were to also occur from
the west portal, trucks or barges could be used. Metro has
identified a number of potential spoils disposal sites, where
the spoil can be used for fill, within the vicinity of the
east portal; these include the American Can site contiguous
to the Renton plant, and the Renton plant itself, which will
require over 250,000 cubic yards of fill (more than the total
volume produced by tunnelling) to implement the recommended
program. If disposal were to occur through the west portal,
the spoils could be trucked to a final disposal site or barged
to the Tacoma industrial area. If spoils are used as fill
for construction sites as planned, impacts at these sites
from spoils disposal will be minimal.
Three Tree Point/Seahurst Park Alternatives. The three
alternative alignments (Routes A, B, and C) would require
approximately 4,000 feet of open-cut construction for force
mains, via a common route through Fort Dent Park, across
the Duwamish River and the West Valley Highway (State Route 181)
to 65th Avenue South. Each of the alternatives would require
a new effluent pump station at the Renton treatment plant
and a second pump station near each outfall location.
118
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A number of potentially significant adverse impacts
are associated with construction of the force main. These
consist of: (1) disturbance of the Duwamish River bed and
temporary degradation of surface water, (2) disruption of
automobile traffic on Interurban Avenue South, (3) noise
and dust from excavation and trucking, (4) disruption of
recreational use of Fort Dent Park, and (5) potential for
encountering archeological resources along the alignment
(particularly in Fort Dent Park). Construction of the outfall
will result in local mortality of marine benthic organisms.
EPA has developed a grant condition requiring Metro
to ensure that a cultural resource survey is completed by
a professional archeologist prior to construction. Any subse-
quent recommendations by the SHPO are to be formally considered.
In addition, Metro will be required to obtain a permit from
the Corps of Engineers under Section 404 of the Clean Water
Act and Section 10 of the Rivers and Harbors Act prior to
any dredge and fill activity or construction in a navigable
waterway. At that time there will be an additional oppor-
tunity for consultation with federal and state fish and wild-
life agencies under the Fish and Wildlife Coordination Act.
The construction impacts specific to each of three tunnel
routes are analyzed below.
Route A (Seahurst Park). Route A, the selected tunnel/
outfall route, requires a 27,000-foot-long tunnel to be con-
structed immediately west of Interurban Avenue South, under
South 146th Street to Seahurst Park.
Major construction impacts would be at the tunnel entrance
and exit points, and to a limited extent along the alignment.
The locations of the tunnel portals are shown in Figures 5-5
and 5-6. Two construction staging areas, one at Interurban
Avenue and the other at Seahurst Park, would be used for
stockpiling equipment, operating compressors and loading
trucks with excavated material (spoil material), if
tunneling begins simultaneously at both portals. Each
staging area would be approximately 40,000 square feet. The
staging area at the park would consist of the entire upper
parking lot, limiting parking during construction to the
approximately 20 spaces at the lower parking lot.
Table 5-3 compares the length of the Seahurst Park tunnel
to tunnel lengths for alternative routes. The major impacts
associated with tunneling include: effects on traffic cir-
culation; localized impacts on air quality, surface water,
and groundwater; and noise. These impacts would occur pri-
marily at the tunnel portals on Interurban Avenue and at
Seahurst Park.
119
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NJ
O
TUNNEL SECTION
IIIIIIIIUIIIIIIHIDIIilll OPEN D
-------
SEAHURST PARK~ BOUNDARY
TUNNELING
20O'-300'
x BELOW SURFACE
SOURCE: METRO , 1981
A
N
£
FIGURE 5-6. WEST TUNNEL PORTAL
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Table 5-3. Comparative Lengths of Tunnels
Route Tunnel Lengths (ft)
Three Tree Point
A 27,000
B 29,000
C 33,000
Alki Point
D 9,200
E 9,200
F No tunneling required
122
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Traffic and noise impacts would be created by truck
traffic at both the east and west tunnel portals. Trucks
would be needed to transport construction materials to the
staging areas, to remove construction spoils from excavation
of the pump station at Seahurst Park (Metro estimates 20-50
truckloads of spoils), and to transport spoils from tunnel
excavation (Metro estimates 35 truck trips per day to transport
400 cubic yards of spoils per day). The total volume of
spoils is estimated to be 160,000 cubic yards, assuming a
13-foot excavation diameter. The current plan is to dispose
of spoils from the east portal only in which case trucks
transporting spoils would not affect the Seahurst Park environ-
ment. In the event spoils are disposed from the west portal,
barges could be loaded with conveyor belts, eliminating truck
traffic increases from spoils disposal.
In addition to the tunnel, an underground outfall would
need to be constructed from the pump station under the park.
A trench as wide as 100 feet would be excavated for this
construction. Rerouting of the creek running through
Seahurst Park may be required during the outfall construction
period. If the creek must be rerouted, short-term adverse
effects on fish and other aquatic species using the creek
are likely-
Once construction is complete, only the tunnel portal
and the pump station would be visible. The tunnel portal
would be secluded in a ravine. The pump station would, however,
be visible from a portion of the park. It would cover an area
of about 10,000 square feet and have a height of up to 20 feet?
the pump station would also require road access. A minor
hum may be discernible in the immediate vicinity of the pump
station, but assuming the superstructure is built with materials
providing sufficient insulation, noise from the pump station
should not be noticeable by users of Seahurst Park.
The cultural resources along the Route A alignment are
unknown at this time. The most sensitive locations will
be at the east portal (Interurban Avenue) and at Seahurst
Park. More detailed cultural surveys will be scheduled once
the alignment is chosen, and SHPO recommendations will be
formally considered in accordance with an EPA grant condition.
Stability of the ground during tunnel construction should
not be a factor because of the deep alignment (maximum depth
450 feet).
123
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Route B (Lake Burien). Route B would include a tunnel
portal west of Interurban Avenue, a tunnel alignment beneath
S.W. 152nd Street, and a second portal near the Puget Sound
shore at the western end of S.W. 152nd Street. Table 5-2
shows the existing land uses for the Route B alignment.
The impacts of Route B tunneling would be similar to
those mentioned for Route A. The most sensitive construction
areas would be the tunnel portals and staging areas, parti-
cularly at the western end of the alignment which would be
located in a residential area.
Route C (Three Tree Point). Route C would include a 33,000'
foot tunnel "cross-country" from Interurban Avenue to Three
Tree Point and tunnel portals at each end of the alignment.
Tunneling would be conducted at varying depths under residential
areas. Table 5-2 shows the existing land uses for the Route C
alignment,
The other impacts of constructing Route C would be similar
to those previously mentioned for Route A. The most sensitive
locations along this route will be Three Tree Point and Inter-
urban Avenue. Some vibration may be felt by residents located
above the alignment, particularly where the depth to the
tunnel is shallowest.
Prior to construction of any outfall, Metro would be
required to obtain permits from the Corps of Engineers under
Section 404 of the Clean Water Act and/or Section 10 of the
Rivers and Harbors Act. Metro would also be required to
obtain shoreline development permits from King County.
Alki Point/Duwgiriish Head Alternatives. The three alter-
nate Alki Point routes (Routes D, E, and F) would require
56,000-63,000 feet of open-cut construction for force mains
and gravity sewer along the Duwamish River from the Renton
treatment plant. Routes D and E would require three pump
stations: one at the Renton plant, a second near Harbor
Avenue, and a third at Alki Point. The two alignments would
have different routes for open-cut construction (east or
west side of the Duwamish River) and a common tunnel route
from S.W. Admiral Way to Alki Point.
Route F would require two pump stations: one at the
Renton plant and the second at Duwamish Head. Route F would
be the same as Route D from the Renton plant to a point just
north of S.W. Spokane Street. Construction impacts specific
to each of the alignments are analyzed below.
124
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Route D (West Duwamish). Route D would require open-
cut construction along Interurban Avenue, West Marginal Way
S.W., Iowa Avenue S.W., and a short segment of the Burlington
Northern Railroad tracks north of Spokane Street. The align-
ment would parallel existing rights-of-way. Table 5-2 shows
the existing land uses fcr the Route D alignment .
Because of the large size of the gravity sewer and force
main, a wide construction trench would be excavated (15 feet
or greater). Construction of such a large trench will have
significant localized impact wherever the right-of-way is
confined by existing structures or utilities.
It is anticipated that there would be a major impact
on traffic circulation and use along portions of the heavily
travelled alignment.
A preliminary evaluation of cultural resources indicates
that there are numerous known archeological sites along the
entire length of the Duwamish River, with one particularly
large site located on both sides of West Marginal Way, in
the vicinity of the proposed pipeline route. A more detailed
cultural analysis would be conducted if this alternative
were selected, in accordance with EPA grant conditions.
The tunnel alignment for Routes D and E would begin
near S.W. Admiral Way, following beneath S.W. Hanford Street,
and terminate at a pump station on Alki Point (see Figure
5-4). The portal and staging areas would be the most affected
by construction activities. Since the existing land use
of the staging and portal areas is primarily residential,
construction activities would be particularly intrusive; these
impacts would be intensified if trucking of spoil material
occurs at Alki Point. Five blocks of open-cut construction
along S.W. Admiral Way would occur.
Route E (East Duwamish.) . The alignment for Route E
would follow the Burlington Northern Railroad and East Marginal
Way, S.W. to S. Idaho Street, where it would cross the Duwamish
River to follow the same alignment as Route D for the remainder
of the distance to Alki Point. Much of the open-cut align-
ment would be constructed through an industrial area and
adjacent to Boeing Field. Table 5-2 shows the existing land
uses for the Route E alignment. Essentially the same con-
struction impacts may be expected as identified for Route D,
except that the river crossing would occur near Kellogg
Island instead of at Fort Dent Park; the U. S. Fish and Wild-
life Service has identified Kellogg Island as an important
wildlife habitat which could be disrupted by construction
of the Route E alignment.
125
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Route F (Duwamish Head). The construction impacts asso-
ciated with Route F from the Renton plant to a point north
of Spokane Street (along the Burlington Northern Railroad
tracks) would be identical to those described for Route D.
Table 5-2 shows the existing land uses along Route F.
From the Burlington Northern Railroad to the point of
outfall, Route F would follow a portion of Florida Street
and Harbor Avenue to Duwamish Head and Alki Beach Park. Con-
struction in the roadways, particularly along Harbor Avenue,
would affect traffic circulation. Access to Alki Beach Park
from Firmount Avenue S.W. to S.W. California Place may also
be affected when construction occurs along that portion of
the alignment.
Land would be required for construction of outfall pump
stations in Alki Beach Park, probably at the northernmost
point of Duwamish Head.
The status of cultural resources along the alignment
is not known. Detailed cultural surveys of the alignment
would be required if this route were selected. Any recom-
mendations of the SHPO would be considered, in accordance
with EPA grant conditions.
For this and all Alki alignments, Metro would be re-
quired to obtain a permit from the Corps of Engineers under
Section 404 of the Clean Water Act and/or Section 10 of the
Rivers and Harbors Act for any dredge and fill activity or
structures in navigable waterways. Metro would also have
to obtain a shoreline development permit from the City of
Seattle.
Summary of Major Construction and Site-Related Impacts of
Final Plan Recommended Program and Mitigation Measures
If the final plan recommended program is implemented,
a decision on the Redmond and North Creek/Hollywood connections
would be deferred. Construction impacts from the present
decision would be limited to the Renton treatment plant site
and the tunnel/outfall route for Seahurst Park. Table 5-4
summarizes major impacts that would occur at these locations,
based on the preceding analyses, and lists available miti-
gation measures. As shown in Table 5-4, if the recommended
program is implemented, Seahurst Park would be the area of
greatest impact.
126
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Table 5-4. Summary of Major Construction/Site Impacts and Available Mitigation Measures
for Final Plan Recommended Program
Geologic and seismic hazards: Soil instability
and seismic hazards could be encountered along
tunnel/outfall route.
J—»
to Spoils transport and disposal impacts: Traffic
~° and potential water quality impacts.
Cultural resources: Archeological remains could
be encountered along tunnel/outfall route.
Recreation: Disruption of recreational uses
of Seahurst Park.
Traffic: Increased truck traffic at Renton
plant and tunnel portals during construction.
Water quality: Potential rerouting of Seahurst
Park creek during construction.
Aesthetics: Pump station at Seahurst Park would
be incompatible with natural park setting.
1) Metro-proposed detailed engineering and geotechnical
studies should include:
a. Identification of areas of soil instability along
route, and siting of facilities or development of
construction methods to reduce soil instability
hazards.
b. Assessment of seismic hazards based on borings
and site-specific seismic investigations, and
development of project design to reduce seismic
risks to acceptable levels.
c. Evaluation of Seahurst Park route, based on
engineering and geologic studies, from the
standpoint of cost, engineering, and risk.
2) If Seahurst Park route not feasible, and another
route selected, supplements to Final Wastewater
Management Plan and EIS should be prepared.
1) Preparation of a final spoils disposal plan.
2) Compliance with DOE limits for sediment discharge
if wet transport is used. ,_
1) Conduct detailed archeological survey of tunnel/
outfall route prior to construction, and consult with SHPO.
1) Scheduling construction activities during off-peak
recreation periods to the extent practicable.
2) Preparation of a construction plan to establish detailed
procedures to reduce recreation use impacts.
1) Rerouting traffic around construction sites and
providing flagmen to ensure traffic safety.
1) Siting of outfall to avoid necessity for
rerouting of creek. If creek must be rerouted,
rerouting should occur during summer months, when
impacts on aquatic life would be least.
2) Preparation of a rehabilitation plan to ensure prompt
restoration.
1) Selection of building design and materials to
minimize visual impacts.
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Impacts of Alternative A-l
Differences from Alternatives A-3/A-5
Alternative A-l includes construction of the following
components, which are also required for Alternatives A-3/A-5:
Redmond connection, North Creek/Hollywood connection, Renton
treatment plant expansion and solids handling facilities.
Impacts of constructing these components have been previously
reviewed.
Alternative A-l differs from Alternatives A-3/A-5 in
the following respects:
o Nitrification facilities would be constructed at the
Renton treatment plant site.
o Solids handling facilities could not be accommodated
on site, and an additional 19 acres would be purchased.
o A tunnel and outfall would not be required.
Thus, compared to Alternatives A-3/A-5, construction
impacts at the Renton treatment plant site would be intensified,
but impacts associated with tunnel and outfall construction
would be avoided. Impacts of the nitrification facilities
and of the additional land required for solids handling are
reviewed below.
Nitrification Facilities
Nitrification facilities would be constructed at the
Renton treatment plant site (see Figure 5-7) , whose existing
environment has been previously reviewed. Construction impacts
of the nitrification and mitigation measures are listed in
Table 5-1; these are similar to the impacts of treatment
plant expansion under Alternatives A-3/A-5 previously described.
Additional Land Required for Solids Handling Facilities
The preferred site for the additional 19 acres required
for solids handling under Alternative A-l is shown in
Figure 5-7. The need for purchase of an additional 19 acres
is an adverse impact of Alternative A-l not shared by the
Alternatives A-3/A-5.
128
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0 100 200 400
^m
SCALE IN FEET
EXISTING
PHASE 1
PHASE 2
FUTURE
Figure 5-7. Renton Treatment Plant Layout:
Alternative Al
SOURCE: Metro, 1980g.
129
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Impacts of constructing the sludge handling facilities on
the site shown in Figure 5-7 would be similar to impacts on
construction at the existing treatment plant site. Most of the
19-acre site, zoned for light industrial use, is vacant, with
the exception of a small warehouse; part of the site is used as
a parking lot. Because the proposed site was not included in
the cultural resources investigation conducted for this EIS, it
is not known whether cultural resources are located there.
If this alternative were selected, a cultural resource inven-
tory would be required prior to construction.
Impacts of Alternative B-l
Difference from Alternatives A-3/A-5
Alternative B-l differs from Alternatives A-3/A-5 in
the following respects:
o The Redmond connection and North Creek/Hollywood
connection would not be required.
o The Renton treatment plant treatment and sludge
handling facilities would be sized to only 72 MGD,
as compared to 99 MGD, but an additional 19 acres
of land would be purchased to maintain flexibility
for future expansion.
o Nitrification facilities would be constructed at the
Renton treatment plant site.
o A tunnel and outfall from the Renton treatment plant
would not be required.
t
o A Kenmore treatment plant would be constructed.
o A tunnel and outfall from the Kenmore treatment plant
to Puget Sound would be required.
Thus, compared to Alternatives A-3/A-5, the construction
impacts of the Redmond connection and North Creek/Hollywood
connection would be avoided, impacts at the Renton treatment
plant site would be intensified (based on the requirement
for purchase of an additional 19 acres), the construction
impacts of the Renton plant tunnel and outfall would be avoided,
and additional impacts would result from construction of
the Kenmore treatment plant and outfall. Construction impacts
of changes at the Renton treatment plant site and of the
Kenmore plant and outfall are reviewed below.
130
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Changes at the Renton Treatment Plant Site
Under Alternative B-l, the Renton treatment plant would
be sized to 72 MGD, and nitrification facilities would be
constructed. Impacts of constructing the facilities at the
Renton plant site required for Alternative B-l are similar
to those previously described for Alternatives A-3/A-5 and
Alternative A-l. The need for purchase of an additional
19 acres is an adverse impact of Alternative B-l not shared
by the preferred program.
Kenmore Treatment Plant
No site has been selected for the Kenmore treatment
plant. Additional site-specific environmental impact analysis
would therefore be required if Alternative B-l is selected.
A Kenmore treatment plant would require about 19 acres for
the 27 MGD capacity planned for Phase 2. Purchase of a 40-
acre site has been proposed. The proposed layout for a Kenmore
treatment plant is illustrated in Figure 5-8.
Construction and site-related impacts of a Kenmore treat-
ment plant are listed and rated in Table 5-1, which also
lists mitigation measures to minimize adverse impacts. Land
use incompatibility and cultural resource impacts are poten-
tially the most important of the impacts listed in Table 5-1.
Neither can be fully assessed until specific sites for the
Kenmore treatment plant are identified. Land use incompatibility
may be a major factor because suitable industrial sites within
the Kenmore area are limited.
Kenmore Treatment Plant Outfall
Alternative B-l would include as a project feature
an outfall tunnel from the Kenmore treatment plant to a point
of discharge south of Richmond Beach County Park. Two alter-
native alignments have been proposed: Route A, beneath N.E.
185th Street, and Route B, beneath N.E. 175th Street. Both
alignments would originate near Bothell Way (State Route 522).
The alignments would be located beneath existing road-
ways for much of their lengths. Existing land use on both
sides of the roadways is primarily residential, with some
commercial and service-related uses. Land use along Bothell
Way is also a mix of residential and commercial. Richmond
Beach County Park is a popular recreation area, as is Log
Boom Park on Lake Washington (proposed site of a pump station)
131
-------
PHASE 1
PHASE 2
FUTURE
PROPERTY LINE
_SCALE IN FEET
0 50 100 200
400
CHLORI NATION/
DECHLORI NATION
D >-DEWATERING
EFFLUENT
PUMPING
SECONDARY
CLARIFICATION
GRAVITY THICK
oo r--;
^-OPERATION
BUILDING
Figure 5-8. Kenmore Treatment Plant Schematic
Alternative Bl (Conceptual 40-Acre Site)
SOURCE: Metro, 1980g.
132
-------
Impacts of constructing force mains and tunnels to the
outfall site near Richmond Beach would be similar to those
defined for the tunnel alternatives to Point Pulley and Alki
Point; see Table 5-1 for a summary of impacts and mitigation
measures. Since neither of the tunnel alignments for this
alternative has been clearly defined, a detailed analysis
of construction impacts is not possible at this time. The
most significant construction impacts would include noise
(from tunneling and staging activities), spoil disposal of
materials excavated from the tunnel, and disruption of recrea-
tion uses at Richmond Beach.
Construction Employment Impacts
Each of the final alternatives would be a major capital
project, and consequently would employ a significant number
of construction workers. The total construction costs of
the alternatives range from $262,200,000 (Alternative A-l) to
$409,900,000 (Alternative A-5). Of the total construction
costs, between $112,200,000 and $243,400,000 would be spent
on labor.
The number of jobs created by this labor expenditure
may be estimated by considering the average hourly wage and
the average number of hours worked in a year by a fully-
employed construction worker. As shown in Table 5-5, the
expenditure on labor may thus be expected to create between
4,050 and 8,770 total person-years of employment. Based on
similar calculations, the final plan recommended program
would require 3,384 person-years of employment. The number
of jobs actually created depends on the duration of con-
struction; for example, if construction lasts 1 year, then
for Alternatives A-3/A-5 4,050-8,770 workers would be needed
at one time, but if it lasts 2 years, then only half that
number, 2,025-4,385, would be needed.
Because each alternative would be constructed in two
phases, however, these jobs will not be created at the same
time. Table 5-6 summarizes the employment effects of each
alternative by phase. It shows, for example, that Alternative A-5
would create 7,480 job-years of employment in Phase 1 but
only 1,290 in Phase 2. The number of people actually employed
would, again, vary with the duration of the construction
project as discussed above and' shown in the table.
This analysis indicates that Metro's plan will create
a large demand for construction workers. Because of the
relatively large size of the construction labor force in
the Seattle area, however, there will probably be little
need for construction workers to temporarily move to the
Seattle area to build the projects called for in the plan.
133
-------
Table 5-5. Total Employment Impacts of Project Alternatives
Alternative
Total construction cost
Labor cost
Q
Hours of work
Job years
Number of jobs if construction lasts
1 year
2 years
3 years
5 years
Note: Figures may be slightly inconsistent because of rounding.
More than one outfall/tunnel alignment is under consideration, and no preferred alternative has been
identified. Therefore, this estimate includes the least cost alternative.
Based on U. S. Environmental Protection Agency Construction Cost Indexes for Urban Sewers, Seattle,
Washington, third quarter, 1979.
f^
Average hourly compensation (wage plus fringe) of $15.00.
Average work year of 1,850 hours (37 hours per week, 52 weeks per year).
Source: David L. Clark, Associate Engineer, Brown and Caldwell, letter to Gruen Gruen + Associates,
June 26, 1980; Washington, State of, Department of Labor and Industries, pers. comm. to Gruen
Gruen + Associates, June 1980; U. S. Department of Labor, Monthly Labor Review, March 1980
(Table 14); Gruen Gruen + Associates.
Al
$262,200
112,200
7,480
4
4
2
1
,000
,000
,000
,050
,050
,025
,350
810
A3
$309,800
174,400
11,626
6
6
3
2
1
a
,000
,000
,667
,290
,290
,145
,100
,260
A5
$409,900
243,400
16,226
8
a
4
2
1
;a
,000
,000
,667
,770
,770
,385
,920
,750
Bl
$322,600
151,400
10,093
5
5
2
1
1
rj
,000
,000
,333
,450
,450
,725
,820
,090
-------
Table 5-6. Employment Impacts of Project Alternatives, by Phase
Alternative Al
Alternative A3
Alternative AS
Alternative Dl
UJ
Ui
Total construction cost
Labor cost
Hours of work
d
Job years
Number of jobs if
construction duration is:
1 year
2 years
3 years
S years
Phase 1
5164,100,000
67,900,000
4,526,666
2 ,450
2,450
1,225
820
490
Phase 2
598,100,000
44,300,000
2,953,333
1,600
1,600
800
530
320
Phase 1
5233, 800, 000a
138,800,000
9,253,333
5,000
5,000
2,500
1,670
1,000
Phase 2
576,000,000
35,700,000
2,380,000
1,290
1,290
645
430
260
Phase 1
5333, 900, OOO3
207,700,000
13,846,667
7,480
7,480
3,740
2,490
1,500
Phase 2
576,000,000
35,700,000
2,380,000
1,290
1,290
645
430
260
Phase 1
5294, 800, OOO3
140,500,000
9,366,667
5,060
5,060
2,530
1,690
1,010
Phase 2
527,800,000
10,800,000
720,000
390
390
195
130
80
More than one outfall tunnel alignment is under consideration; cost estimate included here is for the lowest cost alternative.
Based on U. S. Environmental Protection Agency Construction Cost Indexes for Urban Sewers, Seattle, Washington, third quarter, 1979.
Averaye hourly compensation (wage plus fringe) of 515.00.
Average work year of 1,850 hours (37 hours per week, 50 weeks per year).
Source: David L. Clark, Associate Engineer, Brown and Caldwell, letter to Gruen Gruen + Associates, June 26, 1980; Washington, State of,
Department of Labor and Industries, pers. comm. to Gruen Gruen + Associates, June 1980) U. S. Department of Labor, Monthly Labor
Revieu, March 1980 (Table 14); Gruen Gruen + Associates.
-------
Chapter 6
OPERATIONAL IMPACTS OF ALTERNATIVES
Introduction
This chapter describes the operational impacts of the
long-term wastewater management alternatives for the Lake
Washington/Green River Basins. The alternatives considered
are Alternatives A-3/A-5, Alternative A-l, Alternative B-l,
and no project. Separate sections cover impacts and miti-
gation measures for water quality, aquatic biology, and
fisheries; resource use; growth-related impacts related to
project staging; and recreation.
Under the recommended program in Metro's Final Plan,
capacity would be provided to treat 72 MGD by the year 2000,
rather than the 99 MGD capacity provided by Alternatives
A-3/A-5 in the Draft Plan. Operational impacts which depend
upon effluent volume would be reduced under the recommended
program, as compared to Alternatives A-3/A-5. The operational
impacts described in this chapter for Alternatives A-3/A-5
thus represent "worst-case" impacts that would result if
a decision is subsequently made to divert flows from the
north part of the study area to the Renton plant. It is
anticipated that the difference between 72 MGD and 99 MGD
will not result in significantly different water quality
impacts.
Most of the growth-related impacts associated with the
long-term alternatives are common to all the alternatives.
These growth-related impacts are covered in Chapter 7 of
the EIS.
Water Quality, Aquatic Biology, and Fisheries
Introduction
This section describes the direct impacts of project
alternatives on the Green/Duwamish River and Puget Sound.
Water quality impacts are discussed first, followed by bio--
logical and fisheries impacts. For detailed background
information on the existing water quality and biological
conditions of the Green/Duwamish River and Puget Sound, the
reader is referred to Appendix C in the separately bound
appendices to this EIS.
137
-------
The basis for predicting impacts on the Green/Duwamish
River is existing knowledge of the effects of the Renton
discharge on the river, extrapolated to future conditions
of effluent flow and quality. The "extrapolation" process
ranges in complexity from qualitative estimates to computer
modeling performed by the Washington Department of Ecology
(DOE) .
Much of the basis for predicting impacts on Puget Sound
is the knowledge of the effects of Metro's West Point dis-
charge on the sound. Much of this knowledge was derived
from a series of Metro-sponsored studies conducted from about
1973-1977, the Puget Sound Interim Studies (summarized in
Duxbury, 1976). Also considered are local conditions near
the alternative proposed outfall sites and the potential
cumulative impacts on Puget Sound of the Renton discharge
and other discharges.
The effects of the West Point discharge can reasonably
be used to evaluate the effects of Renton discharge locations
on Puget Sound if the proper qualifications are made to account
for differences in effluent flow and quality, and differences
in current and circulation patterns at the different discharge
locations. Effluent flow at West Point was about 120 MGD
when the Puget Sound Interim Studies were performed, and
treatment consisted (as it does presently) of only primary
treatment. Effluent flow from a Renton discharge to Puget
Sound would be about 100 MGD in the year 2000, and treatment
would be secondary. Differences in currents and circulation
patterns between West Point and the alternative Renton dis-
charge locations are obviously important in using the West
Point discharge as a model for a Renton-Puget Sound discharge;
these differences are considered in this EIS.
Water Quality
Background. The following discussion summarizes the
water quality conditions of Puget Sound and the lower Green/
Duwamish River, and the effects of present treated sewage
discharges.
Although this section focuses on potential adverse impacts
of the alternatives on either Puget Sound or the Green/Duwamish
River, it should be noted that all the alternatives, except
the no-project alternative, will result in improved effluent
quality at the West Point treatment plant. All project alter-
natives include construction of solids handling facilities
at the Renton plant, eliminating the current practices of
transporting solids to the West Point plant, where the
solids cause dry season violations of the plant's NPDES permit
limitations for suspended solids.
138
-------
Puget Sound. Puget Sound is a large inland sea con-
sisting of a series of deep (about 600 ft) basins separated
by relatively shallow (about 150 ft) sills (Figure 6-1).
Three Tree Point has net circulation in a southerly direction,
whereas Richmond Beach has net circulation in a northerly
direction (Metro, 1979e). Alki Point is near the divergence
of northerly and southerly net flows.
The open-water areas of Puget Sound have generally good
water quality. Relatively small depressions in dissolved
oxygen concentration (differences of about 0.3 mg/1) have
been detected in the immediate vicinity of the West Point
outfall (Metro 301 (h) waiver application) . Local increases
in nitrate, ammonia, and phosphate, and local changes in
temperature, dissolved oxygen, salinity, and density, have
been observed directly over the West Point effluent plume
(Duxbury, 1976). None of these changes is detectable more
than 1 mile from the outfall or along the central axis of
Puget Sound. No changes in heavy metals concentrations are
detectable in waters near the West Point outfall (Schell,
et al., 1977).
Concentrations of heavy metals in Puget Sound bottom
sediments have been increasing for about the last 50 years
(Schell, et al., 1977). Urban and river drainages are prob-
ably major sources of heavy metals; however, increases in
lead were found near the Alki Point outfall and increases
in mercury, zinc, and lead were found near the West Point
outfall. High fecal coliform levels in waters of east Puget
Sound beaches prohibit commercial shellfishing there, but
recreational shellfishing is popular, and there have been
no reported adverse public health effects. The relative
contributions of Metro outfalls and other sources (urban
runoff, combined sewer overflows) to coliform violations
have not been identified.
Beneficial Uses in Potential Puget Sound Discharge Areas.
The beneficial uses of Puget Sound near the potential dis-
charge areas are shellfishing, finfishing, contact and non-
contact recreation, navigation, and aesthetic enjoyment.
Among these beneficial uses, shellfishing is probably
the most sensitive to the discharge of treated municipal
wastewater. The use of shellfish resources in the proposed
discharge area is identified in Figure 6-2. Recreational
harvest occurs on virtually all public and private beaches.
The major recreationally harvested species are the native
littleneck and butter clams. Manila littlenecks, cockles,
Macoma, horse clams, and geoducks are also harvested in local
areas (DSHS, pers. comm.). Recreational shellfish harvest
occurs year-round, except for occasional closures due to
paralytic shellfish poisoning. Subtidal geoduck beds that
are of potential commercial harvest value are widely found.
139
-------
Strait of Juan ae Fuca
POSSESSION
SOUND
ADMIRALTY INLET
CENTRAL
PUGET
SOUND
HOOD CANAL
SOUTHERN PUGET SOUND
SOURCE: DUXBURY, 1976
FIGURE 6-1. SUBDIVISIONS OF PUGET SOUND
140
-------
OUWAMISH
HEAD
ALKI
POINT
A
N
-LEGEND-
VASHON
ISLAND
POTENTIALLY HARVESTABLE
SUBTIDAL OEODUCK3
PUBLIC ACCESS INTERTIDAL
SHELLFISHINQ AREAS
ESTIMATED INTERTIDAL RECREATIONAL
USER TRIPS PER YEAR, BY AREA
SOURCES: GOODWIN 1978, SCHOLZ PER8 COMM, DEPT. OF FISHERIES 1978
THREE
TREE
POINT
FIGURE 6-2. SHELLFISH RESOURCES
NEAR POTENTIAL DISCHARGE AREAS
141
-------
Commercial clam harvest is directly regulated by the
Department of Social and Health Services (DSHS). Recrea-
tional harvest is regulated by King County with advisory
input from DSHS. The state water quality standards for fecal
coliform bacteria for commercial harvest are:
Ambient Water: <14/100 ml median; no more than
10 percent of the samples may
have >43/100 ml.
Clam Flesh: <230/100 g
There are no formal toxic metals standards for commercial
harvest or formal standards for recreational harvest, but
DSHS may investigate heavy metals on a case-by-case basis.
Proximity to a wastewater outfall can in some cases be suf-
ficient grounds for decertifying areas for commercial clam
harvest (DSHS, pers. comm.).
Finfishing consists of fishing for a variety of pelagic
and bottom fish, including salmon, rockfish, and flatfish.
More detail on fin fisheries is given later in this chapter
and in Appendix C. Swimming is not widely popular due to
cool water temperatures, but swimming, including snorkeling
and diving, does occur to some degree year-round.
Green/Duwamish River. The Duwamish River is the reach
of the Green/Duwamish River between Tukwila (confluence of
the Black River) and Elliott Bay. The portion upstream of
the confluence is called the Green River (Figure 6-3). The
Renton sewage treatment plant discharges into the Green River
at River Mile 12, about 1 mile upstream of the confluence.
The river water is fresh year-round at the discharge location,
but current reversals due to tidal influence occur during
low flow periods. Salinity from Puget Sound becomes an impor-
tant water quality parameter at about River Mile 6 during
summer low flows (Figure 6-3). The lower 5 miles of the river
are dredged for ship navigation.
The Duwamish River is located in a heavily industrialized
area, and has several water quality problems. Un-ionized
ammonia, dissolved oxygen, temperature, and residual chlorine
in the river have exceeded water quality criteria or standards.
Ammonia from the Renton plant is a major cause of low dissolved
oxygen concentrations, according to modeling studies (Yake,
1980). The temperature of the Renton effluent increases
the frequency of violations of temperature standards in the
river. Although coliform bacteria standards are violated
frequently, Renton effluent does not appear to be implicated
(Bernhardt, 1980). Polychlorinated biphenyls (PCBs) are
present in high concentrations in Duwamish River sediments,
particularly near the mouth of the west waterway (Metro,
1979e). The Renton plant is not a major contributor of
PCBs.
142
-------
RENTON
TREATMENT
PLANT
5.0
DUWAMISH WATERWAY/ESTUARY
(dredged waterway)
6.0 7.0 8.0 9.0 10.0 11.0 1E.O 13.0
LOWER GREEN/DUWAMISH RIVER
SOURCE: YAKE,1980
FIGURE 6-3. LOWER GREEN-DUWAMISH RIVER WITH RIVER MILE INDEX
-------
The DOE has recently adopted administrative rules setting
minimum instream flow standards in the Green/Duwamish River
(DOE, 1980). Minimum flows near Auburn (river mile 32) are
proposed to be 650 cfs for most of the year and 300 cfs in
summer. Present flows actually fall below 300 cfs in late
summer. Minimum flow regulations do not affect existing
water rights.
Beneficial Uses of Green/Duwamish River Discharge Area.
The beneficial uses of the Green/Duwamish River near and
below the Renton outfall are fisheries, industrial water
supply, and navigation. The most critical use with respect
to discharge of the Renton effluent is fisheries. The Green/
Duwamish River is a major producer of chinook, coho and chum
salmon, and steelhead trout. The portion of the river below
the Renton plant discharge is used for adult migration and
juvenile migration and rearing of these species. The
nature and value of the Green/Duwamish River fishery is
described in detail later in this chapter.
Impacts of Alternatives A-3/A-5 on Puget Sound. The
following discussion evaluates the water quality impacts
of Alternatives A-3/A-5 on the Puget Sound discharge area,
and also on the sound as a whole. The two main phases of
effluent dispersion are considered. The first phase is initial
dilution of the effluent in the local vicinity (about 1 mile)
of the diffuser. Initial dilution is controlled by design
details of the diffuser, such as length, diameter, and number
of ports (which has not yet been finally determined); and
locational factors such as depth, density gradient in the
water column, and the direction and velocity of wind-driven
and tidal currents. The second phase is the dispersion of
the initially diluted effluent into the circulating water
masses of the sound, which is a function of net (long-term)
current patterns in the sound as a whole.
Preliminary outfall designs specify discharge depths
of 200 feet at both Alki Point (A-5) and Three Tree Point
(A-3), with initial dilution ratios of at least 100:1; pro-
jected effluent qualities of Puget Sound and Green/Duwamish
River discharges are shown in Table 6-1. in comparison, Metro's
West Point outfall (about 120 MGD) discharges at a depth of 230
feet and achieves an initial dilution of about 100:1 (Schell,
et al., 1977).
Initial Dilution. This discussion evaluates physical
conditions at Alki Point and Three Tree Point for diluting
the Renton effluent. Maximum dilution achievable within
cost constraints is desirable to maintain a margin of safety
for protecting beneficial uses.
144
-------
Table 6-1.
Estimated Influent and Effluent Concentrations
from Proposed Treatment Plants in the Lake
Washington/Green River Basins Study Areaa
Parameter
Total suspended solids
BOD5
Grease
NH -N
NO -N
Total-P
Lead
Zinc
Copper
Total chromium
Total coliform per 100 ml
Fecal coliform per 100 ml
Chloroform
Methylene chloride
Pentachlorophenol
Toluene
I nf 1 uept ,
mg/1
350.
260.
70.
16.
0.1
10.
0.1
1.0
0.2
0.2
500 x 105
40 x 105
5.
35.
13.
20.
Effluent from secondary
treatment plant discharging
to Puget Sound, mg/1
30.
30.
10.
15.
0. 1
7.
0.02
0.07
0.04
0.02
1 , 500 (weekly ave. )
<0.1
30.
13.
3.
Effluent from advanced
secondary plant discharging
to Duwamish, mg/1
15.
15.
5.
1.
15.
7.
<0.02
0.07
0.04
0.02
1,500.
60.
<0.1
30.
13.
3.
Effluent from advanced
wastewater plant discharging
to Duwamish, mg/le
5.
5.
1.
1.
1.
0.5
<0.02
0.04
0.02
0.01
Cn
Developed from "Lake Washington/Green River Basins Wastewater Management Preliminary Plan, "Puget Sound Facilities
Plan, ' and Renton treatment plant records.
An assumed typical value for all proposed treatment plants. Actual concentrations may vary depending on tributary
service areas and treatment plant combinations. Waste load projections for specific service areas and treatment
plants were used for costing alternative schemes.
""Corresponds to the effluent from a Kerunore treatment plant and/or Renton treatment plant which discharges to Puget
Sound. Satellite treatment plants will not produce effluent (i.e., land application systems).
Corresponds to the effluent from a Renton treatment plant with nitrification.
Corresponds to the effluent from a Renton treatment plant with I'-remova \ , N-removal, GAC adsorption, and multimedia
filtration.
Results from one influent and one effluent sample at the H'-nton plant. Source: "Preliminary Toxicant Pretreatjuent
Planning Study," Metru, January 1979.
SOURCE: Metro, pers. comin.
-------
When treated sewage effluent is discharged from a sub-
merged diffuser in seawater, the effluent immediately starts
rising because the effluent is predominantly freshwater and
therefore of lower density than the surrounding seawater.
The effluent does not rise as a discrete mass. Surrounding
seawater is entrained into the effluent plume as the plume
rises. The higher the plume rises, the more dilute it be-
comes, and the more dense it becomes. Seawater loses about
1/100 of its density (expressed in sigma-t units) when mixed
100:1 with effluent.
Whether the plume rises to the water surface is deter-
mined by the presence of a density gradient in the water
column. A density gradient is caused by heating of the sur-
face layers by the sun, or by freshwater (from storm runoff)
in the surface layers. If the density gradient is suffi-
ciently strong, the effluent plume will cease rising and
diffuse out in an underwater layer. If the density gradient
is weak or nonexistent, the plume will rise to the surface
before diffusing out laterally.
The higher the plume rises, the more dilute it becomes.
Thus, for purposes of achieving maximum initial dilution and
bacteria die-off, it is desirable for the plume to rise to
the surface. However, to minimize human and shellfish con-
tact with diluted effluent at the shoreline, it is desirable
that the diluted effluent plume not rise to the surface.
For this EIS, historical depth vs. density data off
Alki Point and Three Tree Point were obtained and analyzed
to determine if one area was superior to the other in terms
of having a stronger density stratification to suppress the
rise of the effluent plume. If the effluent-seawater mixture
at 200 feet is less dense than the surface density, the mixture
(plume) should rise to the surface. Therefore, each set
of depth vs. density data was analyzed by taking the measured
sea water density at 200 feet, subtracting 1/100 of that
density from the measured value (to simulate the mixing in
of the effluent), and determining whether the resultant den-
sity (of the simulated "plume") would be able to rise to
the surface.
The criterion for determining that the plume would not
surface was the existence of measured densities in the over-
lying water column (between 0 and 200 feet) less than the
calculated "plume" value. For example, if the measured
density at 200 feet was 23.23 sigma-t units, the 100:1 effluent
plume would have a density of 23.00 sigma-t units. If the
surface density was between 23.00 and 23.23 sigma-t units,
the effluent would surface. If the surface density was less
than 23.00 sigma-t units the effluent plume would remain
submerged.
146
-------
The results of this stratification analysis by month
are shown in Table 6-2. Density stratification sufficient
to keep the plume from surfacing appears to be consistently
more frequent at Three Tree Point than at Alki Point, on
a month-by-month basis. The percentages given in Table 6-2
are relative estimates and may not accurately depict the
actual incidence of effluent surfacing; effluent plume
behavior is complex.
Initial dilution of 100:1 can probably be attained at
either location, but incidences of the effluent plume rising
to the surface are expected to be less at Three Tree Point.
Metro has performed preliminary modeling of initial dilution
of the effluent off Three Tree Point. The results indicate
that an initial diltuon of 100:1 can be attained under the
range of density gradient strength conditions found off Three
Tree Point.
The work of Bendiner (1976) lends some uncertainty to
the prediction that stratification will prevent surfacing
of the effluent. He found that relatively high concentra-
tions of West Point effluent (up to 270:1 dilution) reached
the shoreline when summer stratification existed over the
diffuser. He theorized that the submerged effluent plume
may be able to "work around the edges" of the density gradient
where, as the density gradient meets the bottom near shore,
a turbulent bottom boundary layer forms and stratification
breaks down locally. During winter, effluent contact with
the shoreline was not found.
Effluent Dispersion. Once the effluent plume has under-
gone initial dilution, its subsequent dispersion is determined
by tidal current patterns and wind-driven currents if the
plume surfaces. NOAA tidal current charts (Figures 6-4 and
6-5) show that, in general, tidal current velocities are
stronger and more predictable near Alki Point than near Three
Tree Point. Thus for purposes of more rapidly dispersing
the effluent plume, the Alki Point area appears superior
to the Three Tree Point area.
Although Figures 6-4 and 6-5 give a general indication
of current speed, they do not indicate the detailed current
directions at the alternative discharge locations. Studies
of local tidal current speed and direction at both locations
have been done on the University of Washington Puget Sound
hydraulic model and on location.
Figure 6-6 shows current directions at the alternative
discharge locations as determined by the University of
Washington Puget Sound model. At Seahurst Park, no appre-
ciable current is seen at lower low water. A shoreward eddy
develops at higher high water and a seaward eddy develops
147
-------
Table 6-2. Vertical Density Differences (200 feet vs. surface) at
Three Tree Point and Alki Point
CD
January
February
March
April
May
June
July
August
September
October
November
December
Three
Number of
Observations
6
8
11
11
12
10
9
6
7
9
9
15
Tree Point
Percent of Time
Weakly Stratified
50
25
10
0
0
0
0
17
14
44
56
60
Alki
Number of
Observations
12
13
13
13
13
9
10
6
5
9
11
11
Point
Percent of Time
Weakly Stratified
67
31
62
38
8
11
0
17
40
78
82
82
Note: The criterion for "weakly stratified" was a vertical difference in sigma-t equal to
or less than 1/100 of the sigma-t at 200 feet. This approximates conditions such
that the effluent plume would surface. (Raw data supplied by E. Collias, Northwest
Consultant Oceanographies, Inc.)
-------
. / V Y^tt&'B
I / ) / '• Ul»
'ff?-' \ n 9/ ,-J^ma
( I I -•
V >' - a v'<™^
M,; (V /5^
^O /*' ^ |\ ^s JCPt. WlllUn* _ UITj
/'/ !\ «
2''a.-KX .' V^ ! V
2 hrs. before
maximum flood
Maximum flood
2 hrs. after
maximum flood
2 hrs. before
maximum ebb
122°.ny -' _ \ ^ /1 .
Maximum ebb
2 hrs. after
maximum ebb
Figure 6-4. Tidal Current Direction and Typical Velocities
Near Alki Point.
Note: Maximum flood and ebb are relative to Admiralty Inlet,
SOURCE: NOAA, 1973a.
149
-------
htttl-H
2 hrs. before
maximum flood
Maximum flood
2 hrs. after
maximum flood
2 hrs. before
maximum ebb
Maximum ebb
2 hrs. after
maximum ebb
Figure 6-5. Tidal Current Direction and Typical Velocities Near
Three Tree Point (Point Pulley).
NOTE: Maximum flood and ebb are relative to the Tacoma Narrows.
SOURCE: NOAA, 1973b.
150
-------
-^ .y ..^ ;•:£*•>!
SEATTLE. JIDEJ
SEATTLE TIDE
Figure 6-6. Surface Current Directions in Central Puget Sound as
Determined by University of Washington Puget Sound Model (pg. 1 of
SOURCE: McGary and Lincoln, 1977.
151
-------
SEATTLE
SEATTLE TIDE
Figure 6-6 (pg. 2 of 2).
152
-------
between higher high and higher low water. Flows parallel
to the shore are present during the maximum flood and ebb.
At Alki Point, shoreward eddies develop at lower low water,
during maximum flood tide and during both ebb tides.
On-location current speed and direction studies were
conducted off Alki Point in 1933 and at Alki, Seahurst Park
(Salmon Creek) and Three Tree Point in 1957 (Brown and Caldwell,
1958). At Alki Point, the data showed onshore eddies on
both sides of the point at certain times of the tidal cycle
(Figures 6-7 and 6-8). At Seahurst Park, shoreward currents
formed during falling tidal stage (Figure 6-9). Onshore
current velocities averaged 13 feet per minute (0.15 mph)
at the surface and 10 feet per minute (0.11 mph) at depths
of 100-200 feet. At Three Tree Point, onshore current eddies
were found during ebb and flood tides at higher tidal ranges
(Figure 6-10). During lower tidal ranges, current conditions
were erratic (Brown and Caldwell, 1958). Shoreward travel
times west of Three Tree Point were found to vary from about
2 hours from 1,000 feet offshore to over 4 hours from 2,000
feet offshore (travel speed about 0.10 mph).
A special study of effluent plume behavior at the alter-
native discharge locations on the University of Washington
Puget Sound model was conducted as part of the facilities
planning/EIS process. The model can provide relative com-
parisons of effluent plume behavior at different outfall
locations. However, the model has several dissimilarities
to actual water behavior in Puget Sound that should be kept
in mind when interpreting results:
o The model underestimates dispersion (i.e., is more
"syrupy" than actual Puget Sound waters).
o Water behavior near the shoreline is not predicted
well.
o Effluent in the model is discharged through a single
point rather than a multipost diffuser.
Following are the general qualitative conclusions of
the modeling study:
o Effluent plume "pooling" in the vicinity of the
discharge occurs to a greater degree, and under a
wider range of conditions, at Seahurst Park than
at Alki Point.
o Dispersal of the diluted effluent plume in the main
body of central Puget Sound occurs more slowly off
the Seahurst-Three Tree Point area than off the Alki
Point area.
153
-------
JULY 7, 1933
H:GH TIDE 241 AM -i.e
LOW TIDE 10 22 AM -16 3
HIGH TIDE 6 06 PM -06
JULY 21, 1933
HIGH TIDE 2 27 A M -3 3
LOW TIDE 10 07 AM -13 9
HIGH TIDE 5 54 PM -I 6
JULY 28,1933
HIGH TIDE 8 23 A M -44
LOW TIDE 2 22 PM -9 6
HIGH TIDE 847 P M -II
AUGUST A,1933
HIGH TIDE I 39 AM -2 I
LOW TIDE 9 20 AM -153
HIGH TIDE 5 00 PM -I I
SEPTEMBER I, 1933
HIGH TIDE 0 44 A M -3 0
LOW TIDE 8 14 A M -13 9
HIGH TIDE 346 PM -15
LOW TIDE 9 08 P M -63
SEPTEMBER 8, 1933
LOW TIDE I 58 A M -I I 9
HIGH TIDE 8 52 A M -3 I
LOW TIDE I 23 P M - 7 9
HIGH TIDE 7 02 PM -J 6
TIDAL HEIGHTS REFERRED TO
SEATTLE CITY DATUM
Figure 6-7. Surface Current Studies off Alki Point.
SOURCE: Brown and Caldwell, 1958.
154
-------
25 JUNE 1957
?4 HCuf CLOCX T. Vt
TiOAL STAGE - 25 JUNE 1957
WEST
; i r. , i i.
12 JULY 1957
RESTOR
POINT
iTIO
IS
^ 10
t 5
\°
N
, i_ STUDY 1- ---*-
^n~- r_ PEH/OD ".T~t im
[
S3&
^
— - - t
^
v1.::
:: : :_•
-"•\::
:-~
~_rr~
-, .-
dOOO ;?00 !400
24 HOUR CLOCK TIME:
TID4L STAGE - 12 JULY 1957
\20 1110
0645 062O
JULY 1957
RESTORATION
- POINT
SC4LE IN FEET
• PATH AND 0'flECnOH Of CURRENT DRAG
TIME
VELOCITY. 'EET PER MINUTE
- DRAGS AT 10 FOOT DEPTH
- DRAGS AT 50 FOOT DEPTH
• GRAGS AT JOO FOOT DEPTH
- DRAGS AT 200 FOOT DEPTH
,DUWAWISH -
HEAD <'
Figure 6-8. Current Studies off Alki Point.
SOURCE: Brown and Caldwell, 1958.
155
-------
^4 HOUR CLOCK r>ME
TID4L STAGE - 15 JUL* '95?
15 JULY 1957
^SEAOLA
N^ \
-//JO \
17 JULY 1957 '
JXC ?CO 2-iOC
TIDAL ST^GE-17 JULY 1957
17 JULY 1957
, PO\HT PULLEY
OHAGS AT 10 foot DEPTH
DRacS AT )0 FOOT DEPTH
DflAGS AT iQO FOOT DEPTH
D»a&s a' ^oo FOOT DEPTH
Figure 6-9. Current Studies off Seahurst Park
SOURCE: Brown and Caldwell, 1958.
156
-------
18 JULY 1957
UOO I'OO
2* HOUR CLOCK TIMS
TIDAL STAGE - 18 JULV 1957
1040 -^
, fe (SOO FT DEPTH)
P01NT PULLEY
19 JULY 1957
*1605 °°CO
24 HOUR CLOCK TIME
TIDAL STAGE -19 JULY 1957
POINT BEALSX
VASHON
OCCO liOO
n HOUH CLOCK nue
TI3AL STAGE -26 JULY 1957
POINT HEYER '•
SCALE IN FEET
TRAMP
' HARBOR
-. PATH AND DIRECTION OF CURRENT DRAG
IS30 TIME
7°. VELOCITY, FEET PER MINUTE
OB405 AT 10 FOOT DEPTH
DRAGS AT 100 FOOT DEPTH
DRAGS AT 200 FOOT DEPTH
DRACS AT 500 FOOT DEPTH
26 JULY 1957
6-10. Current Studies off Three Tree Point (Point Pulley)
SOURCE: Brown and Caldwell, 1958.
157
-------
o Effluent from Seahurst Park moves predominantly north
during high river outflow conditions.
o The Duwamish Head outfall (600 feet deep) gave
slower dispersion than the Alki Point location,
but shoreline contact was minimal.
o The Three Tree Point and Burien outfall locations
resulted in less "pooling" of effluent in the cove
area between Brace Point and Three Tree Point than
did the Seahurst outfall location. Effluent "pooling"
is greatest during neap tides. Effluent may accumu-
late for 4-5 days before being flushed out by spring
tides.
o With diluted effluent circulating through the
southern sound, there was no significant pooling
of effluent in Commencement Bay.
Wind direction and velocity may occasionally appreciably
influence the current patterns described above, particularly
at the surface. All previously reviewed on-location current
studies of the potential discharge areas were conducted during
summer or early fall, when winds are generally light. In
the winter months, the incidence of strong winds is highest,
and the likelihood of the effluent plume rising to the sur-
face where it can be influenced by those winds is also highest,
As shown in Table 6-2, Three Tree Point is weakly stratified
over 50 percent of the time in November through January,
and Alki Point is weakly stratified over 50 percent of the
time in October through January and in March (Table 6-2).
Table 6-3 shows that winds over 10 mph come frequently
from the southwest and south-southwest in December through
March. Harris and Rattray (1954) suggest an average value
of 0.5 knots (0.6 mph) for surface currents generated by
southerly winds (southeast to southwest) in winter. Thus
winter winds may push the surfaced effluent plume field
shoreward faster than current studies would indicate. Shore-
ward travel time for surfaced effluent from a diffuser
located 3,000 feet off Seahurst Park would be about 1 hour
with a current speed of 0.6 mph coming from the southwest.
Shoreward travel time from a diffuser northwest of Alki Point
would be about 7 hours. This shoreward travel would occur
after initial dilution of 100:1 from the diffuser was achieved.
Cumulative Impacts of Alternatives A-3/A-5. This
analysis considers the cumulative effects of the Renton
discharge at the recommended location (Seahurst Park) and
other municipal and industrial discharges to the southern
portion of Puget Sound. Because of net circulation patterns
158
-------
Table 6-3. Predominate Directions of Winds Greater than 10 MPH
at Sea Tac Airport
Predominate Wind Directions
Month (percent frequency of observation)
January
February
March
April
May
June
July
August
September
October
November
December
SSW(21)
SW(12)
SW(20)
SW(22)
SW(15)
SW(20)
NE(10)
SW(14)
N(ll)
NNE(ll)
S(9)
SSW(13)
SW(17)
SSW(ll)
SSW(13)
NE(10)
NE(10)
NE (8)
N(10)
N(7)
NNE (11)
SW(10)
SSW(8)
S(12)
SOURCE: Harris and Rattray, 1954.
159
-------
in Puget Sound, diluted effluent discharged at the Seahurst
Park-Three Tree Point area would be drawn south and around
Vashon Island in a clockwise direction. Some diluted effluent
would probably pass through the Tacoma Narrows and have some
residence time in south Puget Sound. The diluted effluent
would then be drawn up Colvas Passage and be carried north
toward the open ocean. Perhaps 20-25 percent of the diluted
effluent would be recycled south again and around Vashon
Island (Metro, pers. comm.).
The net movement of water volume per unit time in the
counterclockwise direction around Vashon Island is not well
known and probably varies considerably with tidal prism
and season. For discharge planning purposes, Metro is using
a figure of 1,500:1 final dilution of the effluent as it
passes around Vashon Island, including 99 MGD Renton effluent,
200 MGD effluent from other south sound discharges, and 25
percent recycle around Vashon Island.
To compare the pollutant loading of the Renton plant
to other discharges into southern Puget Sound, NPDES permit
data were compiled for all municipal discharges and the major
industrial discharges south of Alki Point. (NPDES permits
are issued to all point-source dischargers by the Washington
Department of Ecology. The NPDES permits specify maximum
allowable pollutant loadings.)
Table 6-4 summarizes the biochemical oxygen demand (BOD)
loading data. Based on present NPDES limits for south sound
discharges and year 2000 Renton projections, the Renton plant
at 72 MGD would contribute 15 percent of the total point
source BOD loading to the south sound; the Renton plant at
99 MGD would contribute 19 percent of the total point source
load. If the planned 1982 reduction in Olympia's BOD loading
is considered, these figures become 25 percent and 31 percent,
respectively. This analysis considers only point source
pollutant loads; if nonpoint source (rivers and urban runoff)
were also considered, the Renton plant contribution for total
BOD loadings would be less.
BOD is used here as an index of overall pollutant loading.
While there are many shortfalls of this approach, since oxygen
depletion is not the water quality effect of greatest concern
in Puget Sound, it appears to be the best way to compare
cumulative loadings based on available data. (Cumulative
heavy metals loadings to Puget Sound are discussed later
in this chapter, and shown in Table 6-6.)
There is virtually no scientific information on the
present cumulative chemical or biological effects of all
discharges to the south sound, mainly because data do not
160
-------
Table 6-4. Pollutant Loading Summary of Renton Alternatives and
NPDES Data for Puget Sound Discharges from Alki Point South
CTi
Year 2000 Renton Alternatives
Renton - 72 MGD1
2
Renton - 99 MGD
Other STPs, Present NPDES Limits
Industrial Discharges, NPDES Limits
Fish Hatcheries
Flow
(MGD) Monthly Average BOD (Ibs/day)
72
99
156
85.5
39.4
19,500
27,000
99,616 (44,766 after Olympia goes
on secondary treatment, December
1982)
14,429
solids)
(6,206 Ibs/day suspended
Capacity provided under final plan recommended program.
"Capacity provided under Alternatives A-3/A-5.
SOURCE: DOE NPDES file data.
-------
exist that could document subtle long-term basinwide changes.
The pollution problems that have been reported in localized
aras of the south sound appear to be related mainly to dis-
charge and leaching of industrial wastes (e.g., Commencement
Bay), not treated municipal wastewater.
Turbidity. Suspended organic solids are the main com-
ponent of turbidity in treated sewage effluent. Turbidity
can potentially affect light penetration, algal production,
and aesthetic values in receiving waters. Suspended organic
solids also can be a source of organic enrichment and toxic
substances.
Discharge to Puget Sound may cause measurable local
turbidity changes. Turbidity is the most detectable water
quality parameter of the West Point discharge (Environmental
Quality Analysts, 1974). The wastewater field and its asso-
ciated turbidity are present at subsurface depths ranging
from 20-50 meters. The turbidity is not associated with
any known adverse impacts.
Because of a higher level of treatment, the turbidity
effects of a Renton plant discharge to Puget Sound would
probably be considerably less than at West Point. The West
Point plant discharges primary effluent with a suspended
solids concentration of about 75 mg/1, occasionally exceeding
120 mg/1 in summer. A Renton outfall would discharge secon-
dary effluent with a suspended solids concentration of about
30 mg/1. There are no apparent advantages or disadvantages
associated with any of the alternative Puget Sound discharge
locations with respect to turbidity
Un-ionized Ammonia. Ammonia is a characteristic product
of treated sewage formed by the decomposition of nitrogenous
organic compounds. The un-ionized form of ammonia, NH3,
is of concern for its potential toxicity to aquatic life.
Un-ionized ammonia is toxic (LC50) to salmonid fishes at
concentrations of about 0.2-0.7 mg/1 (Willingham, et al.,
1979). The 96-hour LC50 for coho salmon in Renton effluent
is 0.45 mg/1 NH3-N (Buckley, 1978).
The State of Washington has not set numerical receiving
water standards for ammonia. The EPA (1976) criterion for
un-ionized ammonia is 0.02 mg/1 for fresh water. Little
information exists on ammonia toxicity under marine and
estuarine conditions, and EPA has not established a criterion
for these conditions.
Under Alternatives A-3/A-5, the Renton discharge to
Puget Sound would not have denitrification in the process
train, and concentrations of total ammonia nitrogen in the
162
-------
effluent would be about 15 mg/1. Un-ionized ammonia is usually
only a small portion of total ammonia. Un-ionized ammonia
is the form of ammonia toxic to aquatic life. Because no
ammonia toxicity problems have been found with the West Point
discharge, no problems are expected to develop for the Renton
plant; rapid initial dilution would probably prevent ammonia
toxicity.
Dissolved Oxygen. Based on data from the West Point
plant, dissolved oxygen (DO) problems are not foreseen with
the preferred program. A local DO sag of about 0.5 mg/1
has been found in the West Point plume (EPA, 1977a). The
West Point discharge is primary effluent, with a biochemical
oxygen demand (BOD) of about 100 mg/1, and flows were about
120 MGD when the DO sag was observed. In contrast, the Renton
discharge would be secondary effluent, with a BOD of about
30 mg/1 and flows would be about 100 MGD in the year 2000.
Thus, very little, if any, DO sag should be noticeable with
a Puget Sound discharge of Renton effluent.
Nutrients. Nutrients in sewage effluent are of concern
because they can stimulate algal growth to levels that are
visually offensive, or that cause DO sags through algal respi-
ration or death. Algal growth in Puget Sound is usually
limited by light, rather than nutrients, so nutrients are
not of great concern for their biostimulatory potential.
Nutrients typically of concern in sewage effluent are phos-
phorus (as orthophosphate) and nitrogen (as ammonia, NH.,;
nitrite, NO^; or nitrate NO-,). There are no numerical state
or federal standards for phosphorus or nitrogen with regard
to algal growth stimulation because levels which would cause
adverse effects vary greatly among water bodies.
Discharge of effluent to Puget Sound would result in
local increases in ammonia, nitrate, and phosphate. Increases
in ammonia are detectable within a radius of about 1 mile
of the West Point outfall (Collias and Lincoln, 1977). Nutrient
concentrations discharged from a Renton plant with secondary
treatment discharging to Puget Sound would be somewhat less
than those from West Point due to the higher degree of treat-
ment involved.
Chlorine Toxicity. Chlorine could be one of the greater
toxicity components of a future Renton discharge into Puget
Sound, as indicated by bioassay tests of the West Point effluent
(Stober, et al., 1977) and of the Renton effluent (Buckley
and Matsuda, 1973). The Renton effluent was found toxic
to coho salmon (96-hour LC50) at a chlorine residual concen-
tration of 0.20 mg/1 (Buckley and Matsuda, 1973).
163
-------
Under Alternatives A-3/A-5, the Renton discharge will
probably have a chlorine residual concentration of about
0.01 mg/1 (Metro, pers. comm. ) . This would meet the EPA
(1976) criterion of 0.002 mg/1 following 100:1 dilution.
Dechlorination could be added if necessary (Metro, pers.
comm . ) .
Baa teria . Violations of coliform standards at east
Puget Sound beaches have not been attributed to existing
treated sewage discharges. Urban runoff is probably a main
cause. There appear to be no direct advantages at any alter-
native Puget Sound discharge site with respect to maintaining
coliform standards. After 100:1 dilution, fecal coliform
bacteria levels in the effluent would be reduced from 1,500/
100 ml to 15/100 ml at a maximum. Levels would actually
be considerably lower due to die-off of the bacteria when
the effluent contacts seawater. The shellfish standard at
the beaches is 14/100 ml. Although the actual fitness of
shellfish for human consumption should not be affected, the
possibility exists that DSHS could decertify subtidal geoduck
beds near the outfall from potential commercial harvest,
as a safety factor for public health.
One benefit associated with the Alki Point alternative
is that combined sewer overflows (CSOs) to the Duwamish estuary
could be intercepted and routed to a discharge point offshore.
The water quality benefits may be marginal. CSOs occur during
or shortly after winter storms, when river flow is high,
and CSO effluent is probably rapidly diluted and carried
into Puget Sound with the high flows.
Me talc,. Heavy metals are of concern for their
acute toxicity to aquatic life, and also for their tendency
to accumulate over time in the flesh of organisms and in
sediments. In one sense, the environment has no assimilative
capacity for heavy metals, since they accumulate in the environ
ment and they do not detoxify or break down.
Table 6-5 shows the effect that a Renton discharge to
Puget Sound would have on background heavy metals concen-
trations after initial dilution (100:1) and dilution after one
tidal cycle (500:1) . These dilution values are approximations
for the West Point discharge from Schell, et al. (1977).
Table 6-5 also shows numerical EPA (1976) receiving water
criteria. It is evident from Table 6-5 that the Renton dis-
charge would increase heavy metals concentrations in Puget
Sound by a small amount.
164
-------
Table 6-5. Effect of Renton Effluent on Heavy Metals Concentrations in ug/1, in Puget Sound
(Ti
Background
Concentration1
Renton Effluent
(Jan 1978-Sep 1979) 2 Receiving Water Concentration
EPA
Criterion3
Cadmium 0 . 36
Chromium
Copper 0.57
Lead 3.68
Mercury -
Nickel 1.33
Zinc 2.3
Average
<4
20
30
< 20
1.4
30
40
After Initial
Range Dilution (100:1)
< 4 < 0.40
10-30
20-60 0.86
<20 3.84
0.3-2.8
10-40 1.61
30-60 2.67
After 1 Tidal
Cycle (500:1)
< 0. 37 5.0
18
(h exavalent)
0.63 40
3.71
0.025
1.39 7.1
2.38 58
1SOURCE: Huntamer, 1976 in Schell, et al., 1977.
2 SOURCE: Metro, 1979d.
3SOURCE: Federal Register, November 28, 1980. Values are 24-hour averages.
-------
Table 6-6 compares projected copper, lead, and zinc
loading to Puget Sound from the Renton discharge to other
sources of these metals. The Renton contribution would again
be relatively small. Loadings for other metals are not
available.
Although a Renton discharge to Puget Sound would contri-
bute some heavy metals, no direct adverse effects are expected
in light of the great dilution that would occur in Puget
Sound and the relatively small portion of the total metals
load that the Renton discharge would contribute. In general,
heavy metals in wastewater effluent tend to adhere to fine
particulate matter which coagulates and settles when dis-
charged into sea water. Settling of fine particulate matter
generally occurs in areas of relatively low slope and slow
tidal current velocity. Settling of particulate matter will
probably occur within the immediate vicinity of the discharge.
Some particulates may also be transported to areas farther
away from the immediate discharge vicinity that are "deposi-
tional", i.e., areas of slow current velocity where fine
sediments tend to settle. Depositional areas in estuaries
are generally evidenced by a high percentage of fine sedi-
ments that have a high water content (i.e., "fluffy").
Figure 6-11 shows bottom sediment types in the proposed dis-
charge areas. The "mud" area along the central axis of the
sound would be a depositional environment for heavy metals.
Because the preliminary outfall length is about 3,000 feet,
effluent would not be discharged directly over the depositional
muds, but some metals from Renton effluent would eventually
be transported to this area.
Toxic Organic Substances. The potential effect of toxic
substances in Renton effluent on Puget Sound water quality
is unknown. There is little existing information on either
toxic organic substances in Puget Sound or the effects of
chlorination of Metro discharges on the formation of toxic
organic compounds.
In 1979, organic compounds were sampled in Hylebos Water-
way near Tacoma (Riley, et al., 1980). Six chlorinated com-
pounds and five aromatic compounds identified were on EPA's
list of priority pollutants. In the same study sampling
in Elliott Bay revealed relatively small or undetectable
amounts of saturate and aromatic hydrocarbons, and there
was no attempt to identify them. It appears that these prob-
lems are related mainly to industrial waste discharges and
not to discharge of treated municipal wastewater. Metro
is presently starting a 3-year toxicant study which will study
toxicant sources, treatment processes, and fates in the
environment.
166
-------
Table 6-6. Estimate of Yearly Copper, Lead, and Zinc Input to Puget Sound
for a Renton Plant Discharging at 100 MGD, Compared to Other
Sources at Present Levels
CTi
Copper
Renton- Year 2000
Rivers
Seattle Urban Runoff
Metro West Point Plant
Other Municipalities
Total
Metric
Tons
6
787
15
29
22
859
Percent
1
92
2
3
3
Lead
Metric
Tons
3
2,032
350
9
16
2,410
Percent
0.1
84
15
0.4
0.7
Zinc
Metric
Tons
10
1,624
50
56
26
1,766
Percent
0.
92
3
3
1
6
SOURCES: Metro, pers. comm.; Schell, et al., 1977.
-------
Mud ond Sand
Mud- Sand- Grovt!
Hardpan
Clou Nom« Par licit Dlom«t*r
G'Ortl Lorgtr ihon 2 00 mm , 0 0787 in
So*4, 063-200mm. 0 0025 - 0 0787 n
Wu
-------
Impacts of Alternatives A-3/A-5 on Green/Duwamish River.
Alternatives A-3/A-5 will remove the Renton effluent from
the Green/Duwamish River. Although the intended effect is
to improve water quality in the river, the hydrologic and
water quality effects of effluent removal, especially in
relation to other proposed actions in the river, warrant
examination. These topics are analyzed below.
Hydrologic Effects. Removal of Renton effluent from
the lower Green/Duwamish River would cause hydrologic changes
in the estuary due to the lower volume of water flowing through
it. Renton effluent enters the river at mile 12 (Figure 6-3).
Salt water in the estuary is encountered about mile 8 in
the low flow season (late summer). The river below mile
12 is tidally influenced; thus the effects of 50 cfs low
salinity flow from the treatment plant are on net downstream
curient velocity and salinity repulsion; river depth and
width would be affected very little.
Figure 6-12 shows existing conditions and the effects
of future alternatives on net outflow. Present flows would
be reduced by about 18 percent if the effluent is removed
from the river.
Water Quality Effects. The present Renton discharge
aids in flushing the Green/Duwamish River, yet it also adds
its own pollutants. Effects of removing the effluent from
the river must be explained in terms of dissolved oxygen
(DO) concentrations at the water surface and at depth.
Minimum DO concentrations are generally found at the
bottom in the vicinity of river mile 4.8 (16th Avenue South
bridge). In August-October of 1976-1980, bottom DO concen-
trations at mile 4.8 averaged 5.3 mg/1 but always exceeded
3.5 mg/1. This location corresponds with the toe of the
saltwater wedge during the low flow period of the year
(Figure 6-13). Lack of mixing with surface waters due to
freshwater/saltwater stratification is a contributing factor
toward the low DO. Lowest bottom DO are found at times of
lowest stream flow and lowest tidal range (Figure 6-14).
Minimum bottom DO is apparently related to water retention
time (Santos and Stoner, 1972). Freshwater flow plays a
role in driving the mixing of fresh and salt water in the
wedge.
DO conditions in the wedge do not appear to have changed
significantly since 1970; however, surface DO has exhibited
periodic sags in recent years (Harper-Owes, 1981). Ammonia
in the river from Renton effluent has increased steadily
over this period (Figure 6-15) , so it appears that ammonia
from the Renton plant has caused or contributed to these
depletions (Harper-Owes, 1981; Yake, 1980).
169
-------
700
600 —
<
s!
oc
UJ
CO
UJ
CE
I—
co
500 —
400 —
300 —
200 —
100 —
ALTERNATIVE A-1,99mgd
ALTERNATIVE A-l, 72mgd
EXISTING CONDITIONS
REMOVE EFFLUENT
-LEGEND-
1-IN-2 YEAR FLOW
•— 1-IN-10 YEAR FLOW
JULY AUGUST SEPTEMBER
MONTH
SOURCE'• Compiled From Metro & USGS Doto
FIGURE 6-12. EFFECTS OF RENTON
TREATMENT PLANT ALTERNATIVES
ON DRY SEASON FRESHWATER FLOWS
IN GREEN-DUWAMISH ESTUARY
170
-------
0
4
8
12.
RIVER KILOMETRES
6 8
10
12
Solinity, in parts per thousand
RIVER MILES
SOURCE: PRYCH , el al 1975
-2
Temperature, in degrees Celsius
Dissolved-oxygen concentration
in milligrams per litre
J-12
FIGURE 6-13. OBSERVED LONGITUDINAL
PROFILES OF SALINITY, TEMPERATURE,
AND DISSOLVED-OXYGEN CONCENTRATION
IN THE DUWAMISH RIVER ESTUARY
DURING THE LOW HIGH TIDE OF
SEPTEMBER 13, 1968
171
-------
0 2000
Q 2
JUNE
JULY
AUGUST
SEPTEMBER
FROM: SANTOS & STONER, 1972
FIGURE 6-14. MEAN DAILY FRESH-
WATER INFLOW, TIDAL-PRISM
THICKNESS, AND MINIMUM BOTTOM
DO, AT STATION 7.7, JUNE-
SEPTEMBER 1966
172
-------
1.6 -
1.2 -
z
Z 0.8
0.4 -
i
§
•*t V)
*o *o
cs o^
K oo cs o
*O *O *O t^s
0s 0s O** &^
CN| CO
^^ r**s
co o- o
YEAR
SOURCE'. HARPER-OWES, 1981
FIGURE 6-15. (±1 STD DEV.) AMMONIA
CONCENTRATION AT 16th AVENUE SO.,
SURFACE DURING JUNE TO SEPTEMBER
173
-------
The water quality effects of removing the Renton effluent
may be to decrease DO concentrations in the wedge due to less
estuarine circulation, but increase DO concentrations at
the surface due to a removal of the ammonia. It is not pos-
sible with present information to quantify the effects on
wedge DO. Surface DO improvements are approximated by model-
ling performed by Metro staff (pers. comm.). Under present
conditions, modelled low DO in the surface layers was 5.5 mg/1;
low DO with effluent ammonia removed (nitrified) was 8.4 mg/1.
Effluent removal will lower the incidence of temperature
standards violations below the Renton plant by about 4 percent
in August.
Combined Effects of Tacoma Diversions from Green River.
The City of Tacoma plans on doubling its water diversion
capacity from the Green River to augment its municipal and
industrial water supply (Economic and Engineering Services,
Inc., 1980). However, new diversions must comply with minimum
flows set by DOE for the Green River at Palmer, even though
existing river operations are not consistent with these DOE
minimum flows. In other words, the new diversions must not
allow flows to diminish below the DOE standards at Palmer,
but the existing diversions may continue permit flow to fall
to present levels.
The modelled flow duration curves for existing and future
Green River discharge conditions are shown in Figure 6-16.
The greatest effects are at flows intermediate between high
and low flows. Flows lower than the 82nd percentile of
exceedence at the Palmer gage are not affected. It is rea-
sonable to assume that flows below the 82nd percentile of
exceedence at the Tukwila gage (about 420 cfs) will likewise
not be affected. Thus, flows of less than about 420 cfs
into the estuary (not including Renton effluent) will not
be affected by increased Tacoma diversions.
These data indicate that the frequency of lowest DO
concentrations in the wedge is not expected to change due
to the Tacoma diversions, although the frequency of inter-
mediate concentrations may increase. The diversions may
compound possible effects of removal of Renton effluent on
wedge DO concentrations, but only under intermediate flow
conditions and DO conditions. Under "worst case" flow and
DO conditions (at flows less than 420 cfs), the diversions
are not expected to affect flow or DO.
Combined Effects of Dredging Projects. The U. S. Army
Corps of Engineers is proposing to dredge the Duwamish water-
way to improve navigation. Harper-Owes (1981) found that,
although wedge water residence time in the channel would
be increased, effects on wedge DO would be minimal (0.05
mg/1), because oxygen demand in the wedge is mainly in the
174
-------
100.
80. _
A|
>-
o
o
LJ
OL
60. _
40. _
20. _
0.
500 1000 1500 2000 2500 3000 3500 4000
DISCHARGE cfs
FROM: CHARLES HOWARD & ASSOCIATES. 1980
FIGURE 6-16. FREQUENCY COMPARISON OF
PALMER FLOWS FOR TACOMA DEMANDS OF
76 AND 144 MOD
-------
bottom sediments. In this case, the dredging project would
not worsen any effects that removal of Renton effluent may
have on wedge DO.
Combined Effects of Eastside Green River Watershed
Project. The U. S. Soil Conservation Service is proposing
a comprehensive set of structural and nonstructural measures
to reduce flooding in the Black River drainage. Channelization
will increase the capacity of the existing P-l discharge
pump structure. Pumped discharges to the Green River will
occur during flood flows (USSCS, 1970). Thus, water quality
problems in the Green/Duwamish River during the low flow
season would not be affected, and there would be no worsening
of any effects that removal of Renton effluent may have on
wedge DO concentrations.
Impacts of Redmond Connection Emergency Bypass. One
feature of the Redmond connection, proposed as part of
Alternatives A-3/A-5, could adversely affect water quality.
This is an emergency bypass from the York pump station dis-
charging to the Sammamish River. The emergency bypass would
be designed to operate in the event of failure at the Totem
Lake pumping station, which is considered by Metro to be
an event of remote probability- Sewage would be bypassed
to the Sammamish River in such an event. Under the final
plan recommended program, the decision to build the Redmond
connection would be deferred. Emergency bypass impacts would
therefore not result from the present decision.
If an emergency bypass were to occur, untreated sewage
would enter the Sammamish River near N.E. 124th Street. De-
pending upon the quantity and duration of the discharge,
such an event could cause a DO sag and an increase in ammonia,
phosphate, and nitrate. The significance of the reduction
in DO would depend on the BOD loading and rate of flow in
the river.
An uncontrolled discharge during the low-flow summer
months would have a greater impact on water quality than
if such an event occurred during the winter or early spring.
It is during those summer months that water quality condi-
tions in the Sammamish River are most critical. Under normal
conditions water temperatures and DO levels often violate
the standards due to the low flows and velocity of the river.
A discharge of untreated sewage would also cause an increase
in coliform bacteria and nutrients which could cause nuisance
problems or possible health hazards.
176
-------
If the discharge of untreated sewage into the Sammamish
River was substantial enough, aquatic species would be adversely
affected. The most likely effect of nutrient loading would
be a stimulation of algae or rooted aquatic plants in the
sluggish portions of the river and where the river enters
Lake Washington. A substantial inflow of sewage could cause
mortality to invertebrate and fish populations downstream
of the York pump station.
The probability of an emergency bypass from the Redmond
connection would be very low, because the York pump station
would be provided with emergency power generation equipment.
Impacts of Alternative A-l The following discussion
evaluates the water quality impacts of Alternative A-l, which
calls for installation of nitrification processes at the
Renton plant and continued discharge to the Green/Dawamish
River. Effluent dispersion, turbidity, un-ionized ammonia,
DO, nutrients, heavy metals, chlorine toxicity, bacteria,
toxic substances, and temperature are considered. When
relevant, water quality improvements that would result from
installation of advanced waste treatment under Alternative A-2
are noted.
Stream Flow. Hydrologic effects on summer low flows
in the Green/Duwamish River at 72 and 99 MGD are shown in
Figures 6-12. Monthly average l-in-10-year low flows into
the estuary would be increased by about 25 percent over present
conditions if Alternative A-l were implemented and year 2000
flows were 99 MGD.
Effluent Dispersion. Initial dilution of effluent
from a continued Green/Duwamish River discharge would be
poor. Presently, river-to-effluent dilution ratios in
the Green/Duwamish River are as low as 4:1, and "slugs" of
river flow can be as high as 58 percent effluent due to
repeated passage of a block of water past the discharge area
due to oscillating tidal action. A general rule-of-thumb
guideline promulgated by the Washington Department of Ecology
for an acceptable river-to-effluent dilution ratio is 20:1
(Bernhardt, 1980).
In the year 2000, with a minimum summer instream flow
of 225 cfs and a Renton effluent flow of 100 MGD, the river-
to-effluent ratio would be reduced to 1.5:1. Thus the river
would average 40 percent effluent in the freshwater reach
(about 6 miles) below the discharge during summer low-flow
periods. "Slugs" of river water with effluent concentrations
as high as 70 or 80 percent would probably exist.
The DOE (1980) has recently adopted rules calling for
minimum flows of 300 cfs in the Green River at Auburn. Pre-
sent low flows are about 200 cfs. A clear agreement on how
additional flows will be gained is not defined.
177
-------
Effluent residence time in Puget Sound for a Green/
Duwamish discharge would probably be about the same as for
Alternatives A-3/A-5 with an Alki Point discharge.
Turbidity. Recent data indicate that turbidity from
the Renton plant has a "slight impact" on the Green/Duwamish
River (Bernhardt, 1980), though no beneficial use is affected.
Turbidity from an expanded plant with nitrification (Alterna-
tive A-l) would probably continue to have a slight affect.
Alternative A-2 would probably produce a very clear effluent
with minimal turbidity impacts due to the filtration process
to be used.
Un-ionized Ammonia. The Renton discharge presently
causes violations of the EPA 0.02 mg/1 criterion in the Green/
Duwamish River. Sampling in September 1979 showed values
as high as 0.105 mg/1 (Bernhardt, 1980).
Nitrification of the discharge into the Green/Duwamish
River would reduce the effluent concentration of total ammonia
nitrogen from present levels of about 15 mg/1 to 1 mg/1.
This decrease would probably eliminate the present violations
of un-ionized ammonia criteria in the Green/Duwamish River.
The nitrification process in sewage treatment can be
difficult to initiate and maintain. Any upset in the nitri-
fication process could create toxic ammonia conditions in
the Duwamish River or cause BOD and SS violations due to
poor settling. Maintenance of only seasonal nitrification
might be especially difficult.
Metro (pers. comm.) staff has performed calculations
which show the effects of ammonia concentrations on fish
under future conditions of effluent flow (99 MGD) if the
effluent were not nitrified. These calculations also approxi-
mate the effects of nitrification process upset under Alter-
native A-l. The calculations show that at a river pH of
8.5, 95 percent of all coho salmon would be killed within
5 hours. Conditions of pH 8.5 occurred in 1974 and 1975,
and pH values as high as 9.0 occurred in 1965 and 1966 (Welch
and Trial, 1979). For unknown reasons, high pH values have
not occurred in recent years. Future high pH values due
to algal blooms certainly should not be ruled out.
Dissolved Oxygen. Adequate levels of DO are essential
for fishes and other aquatic organisms to survive. The state
DO standard in the tidally influenced reach of the lower
Green/Duwamish River is 8.0 mg/1 above the Black River (Class A)
Below the Black River (Class B), the standard is 6.5 mg/1
or 70 percent saturation, whichever is greater. DO standards
are 6.0 mg/1 in Elliott Bay and 7.0 mg/1 in central Puget
Sound.
178
-------
Present discharges from the Renton plant are at least
partially responsible for DO standard violations in the lower
Green/Duwamish River. Organic matter from plankton blooms
has been thought to be the source of oxygen demand which has
caused oxygen sags (Welch, 1969; Welch, et al., 1972; and
Welch, 1980; in Welch and Trial, 1979). Recent modeling
studies (Yake, 1980) concluded that instream nitrification
due to ammonia in the Renton effluent is a principal contri-
butor to the DO sag. Carbonaceous BOD from the Renton plant
apparently is relatively unimportant in the DO sag problem
(Yake, 1980).
Figure 6-17 shows field DO concentrations taken in fall
1971, mathematical modeling curves simulating those conditions,
and a mathematical modeling curve for DO under 1985 conditions
(upriver flow - 210 cfs; effluent flow - 63 MGD) with no
nitrification (effluent ammonia - 15.2 mg/1). The 1985
modeling results indicate that without nitrification, DO
standards violations would be more severe than they are pre-
sently, with values as low as about 3 mg/1 in the brackish
water reach. Metro (pers. comm.) has performed calculations
showing DO as low as 1.5 mg/1 in the year 2000 without nitri-
fication .
Continued discharge to the Green/Duwamish River with
nitrification (Alternative A-l) would probably alleviate
any DO sag due to ammonia in the effluent. Under this alter-
native, the ammonia nitrogen concentration in the Renton
effluent would be reduced from about 15 mg/1 to 1 mg/1.
Nutrients. A nitrified discharge to the Green/Duwamish
River (Alternative A-l) would continue to discharge nutrients
to the river at present concentrations (about 15 mg/1 N;
about 7 mg/1 total P), but effluent flows would be higher
(about 100 MGD in the year 2000 vs. about 40 MGD today).
Effluent with advanced waste treatment (Alternative A-2)
would have lower nutrient concentrations (about 2 mg/1 N;
about 0.5 mg/1 P) than the present discharge.
Heavy Metals. Input of heavy metals to the Green/Duwamish
River under Alternative A-l would be about the same as the
input to Puget Sound under Alternatives A-3/A-5. Most of
the quantities of heavy metals discharged to the river would
be transported to Puget Sound by river flow. Some may settle
out due to flocculation processes in the Duwamish estuary.
There have been no studies of effects of heavy metals
on Duwamish River sediments or biota. However, DOE
recently estimated heavy metals effluent limits which it
believes are necessary for receiving water aquatic life
179
-------
10
9 -
— 8
7 -
cr 6-
o
z
o
o
X
o
o
UJ
o
co
CO
5 -
4 -
3-
- 5/75
MOD ft 9/18 -19/ 79
i- «..
WATER QUALITY STANDARD
• FRESHWATER-
••-0-40% SALTWATER •—•-
•>40% SALTWATER
13
I
12
I
11
I
10
RIVER MILES FROM MOUTH
ND-
• 9/18-19/79
-•- 10/2 3/79
FIELD DATA
SOURCE:YAKE,1980
FIGURE 6-17. FIELD DATA & MATHEMATICAL MODELING RESULTS
FOR DISSOLVED OXYGEN IN GREEN - DUWAMISH RIVER
180
-------
based on a 20:1 effluent dilution ratio. Table 6-7 compares
these limits to existing discharge levels. Existing effluent
levels considerably exceed the copper, mercury, and zinc
limitations. Continued discharge under Alternative A-l would
continue this situation.
Advanced waste treatment (Alternative A-2) would reduce
effluent concentrations of chromium, copper, and zinc by
about half compared to the other alternatives (Metro, pers.
comm.). Data for other metals are currently unavailable.
Chlorine Toxicity. Although dechlorination has been
added to the Renton plant (1973) , violations of the EPA (1976)
water quality criterion of 0.002 mg/1 have been found. In
November 1979, values as high as 0.19 mg/1 were found in
the immediate vicinity of the discharge, and values as high
as 0.07 mg/1 were found about 1 mile downstream (Bernhardt,
1980) .
Part of the chlorine toxicity problem may stem from
the type of dechlorination system at the Renton plant. The
plant has a "feedback" system, which, in order to function
properly, cannot totally dechlorinate the effluent (DOE,
pers. comm.).
Continued discharge to the Duwamish River could result
in continued residual chlorine violations, unless better
dechlorination or alternative effluent disinfection processes
were installed. Metro is presently investigating different
methods to improve the Renton plant's chlorination system.
Bacteria. Coliform standards are frequently violated
in the lower Green/Duwamish River. Nonpoint source pollu-
tion and CSOs appear to be the main contributors. Continued
Renton discharge to the Green/Duwamish River would probably
not cause violations unless temporary failures in the chlori-
nation process occurred.
Toxic Organic Substances. High levels of polychlorinated
biphenyls (PCBs) have been found in Duwamish estuary sediments
and fishes (Metro, 1979e). The major sources appear to be
accidental spills, and nonpoint source runoff. The Renton
plant is probably not a significant contributor of PCBs to
the estuary- Continued discharge to the estuary would prob-
ably have little or no effect on PCB concentrations. There
is little information on other toxic organic substances in
the estuary, such as the effects of chlorinating the Renton
effluent on the production of trihalomethanes and other organo-
chlorine compounds. Metro is now starting a 3-year toxicant
study which will investigate toxicant sources, treatment
processes, and fates in the environment.
181
-------
Table 6-7. Effluent Limits Estimated by DOE to Protect Water Quality
and Average Existing Effluent Concentrations for the Renton Discharge
CD
I\J
Cadmium ug/1
Ib/day
Chromium ug/1
Ib/day
Copper ug/1
Ib/day
Lead ug/1
Ib/day
Mercury ug/1
Ib/day
Nickel ug/1
Ib/day
Zinc ug/1
Ib/day
Estimated Effluent Limits
1.6
4. 8
10. 0
30.02
2.40
21
6. 31
0.2
0.06
100
30.02
4
1. 20
Existing Effluent Average1
(January 1978-September 1979]
< 4
. 18
20
5.9
30
10.3
< 20
3.8
1.4
0.47
30
40
12.2
'SOURCE: Metro, 1979d.
-------
Temperaturc. State temperature standards are violated
annually in the Duwamish River estuary and about 1 year in
2 in the lower Green River. The temperature and flow of
the Renton effluent probably increases the frequency and
magnitude of temperature standard violations. Continued
discharge to the river under increasing effluent flow condi-
tions would cause the frequency and magnitude of violations
to increase in the future.
The temperature standards of the Washington DOE for the
freshwater portion of the lower Green/Duwamish River are:
o Confluence of Black River upstream to the limit of
tidal influence (Class A): temperatures shall not
exceed 18.0°C (due to human activities). Tempera-
ture increases shall not, at any time, exceed t=28/(T+7).
When natural conditions exceed 18.0°C, no temperature
increase will be allowed which will raise the receiving
water temperature by greater than 0.3°C.
o Confluence of Black River downstream to mouth (Class B):
temperature shall not exceed 21°C due to human activities
Temperature increases shall not, at any time, exceed
t=34/(T+9). When natural conditions exceed 21.0°C,
no temperature increase will be allowed which will raise
the receiving water temperature by greater than 0.3°C.
To determine the frequency of background water tempera-
ture violations and to evaluate the potential effects of
the Renton discharge on the frequency and magnitude of present
and future violations, river flow and temperature data, and
Renton effluent flow and temperature data, were obtained and
analyzed. The impact of present and year 2000 Renton effluent
flows on river temperature was estimated based on conservation
of heat between the effluent and river flows. This method
is rough, and does not account for the dynamic processes
of evaporation, shading, advection, conduction, radiation,
and water velocity that occur in the water masses.
The time period selected for analysis was the month
of August, for the years 1967, 1970, 1971, 1972, and 1974-
1978. Daily Green/Duwamish River flow data were from the
USGS gage at Tukwila. Daily maximum temperature data were
from Metro station 311, at the same location. Daily tempera-
ture and flow data were obtained from Metro. The results
of the temperature analysis are described below:
o Background temperature exceeded the 18°C standard on
77 percent of all August days.
o Addition of the Renton effluent caused the standard
to be exceeded an additional 4 percent of all days,
for a total of 81 percent.
183
-------
o Effluent temperatures were generally 20-22°C. On days
when the maximum background temperatures approached
effluent temperatures, the effects of the effluent
lessened. On 24 percent of all days, effluent tempera-
ture was actually cooler than background river tempera-
ture. These were generally days when background river
temperatures exceeded 20-22°C.
o At year 2000 effluent flow levels, the standard would
be exceeded an additional 12 percent of all days, for
a total of 89 percent.
Impacts of Redmond Connection Emergency Bypass. Under
Alternative A-l, Redmond connection emergency bypass
discharges to the Sammamish River may occur. The impacts
of these emergency discharges have been described in the
water quality analysis of Alternatives A-3/A-5.
Impacts of Alternative B-l. Alternative B-l includes
dual treatment centers: the existing Renton plant, and a new
Kenmore plant which would discharge to Puget Sound via a
Richmond Beach outfall. This discussion will focus on how
the impacts of dual treatment centers would differ from those
of centralized treatment.
A Richmond Beach outfall 200 feet deep would probably
have minimal effects due to low flow and the residential
origin of the wastewater. Viewing Puget Sound as a whole,
Alternative B-l would achieve better dispersion of Renton
service area effluent than the preferred program or
Alternative A-l because the effluent would enter from two
widely separated sources rather than from a single source.
Residence time of the diluted effluent in Puget Sound would
be shorter for Richmond Beach than for any of the other dis-
charge locations.
Another advantage to Alternative B-l, compared to
Alternative A-l, is that of reduced water quality impacts on the
Green/Duwamish River. Under Alternative B-l, year 2000 flows
to the Green/Duwamish River would be 72 MGD, vs. 99 MGD for
Alternative A-l. Even with this reduced flow, however, the
water quality problems predicted for Alternative A-l would
occur with Alternative B-l, with a lesser degree of severity.
Impacts of No Project. Major adverse ammonia and DO
impacts would occur in the Green/Duwamish River if no project
is constructed and flows continue to increase. Without nit-
rification, un-ionized ammonia would probably exceed by far
the EPA (1976) criterion of 0.02 mg/1. Welch and Trial (1979)
found that, even at present levels of ammonia discharge,
the un-ionized ammonia concentration would exceed 0.5 mg/1
if pH were 9.0 and temperature were 20°C (conditions observed
in the river in 1966) .
184
-------
DO levels in the estuary would decrease due to increasing
ammonia and BOD loadings. BOD would especially increase
because the present treatment facilities could not adequately
treat year 2000 flows. Present effluent BOD concentration
is about 15 mg/1 at 36 MGD during dry weather conditions.
This loading may increase to 30 mg/1 by 1985 and would become
considerably greater by the year 2000. The Renton plant
could probably give essentially primary treatment to year
2000 flows. DO levels in the estuary during dry weather
would probably approach 0, as they did in past decades before
direct pollutant sources to the estuary were abated.
Aquatic Biology and Fisheries
Background. The biological resources of Puget Sound
and the lower Green/Duwamish River and the known impacts
of Metro wastewater facilities on those resources are
summarized below.
Puget Sound. Puget Sound can be separated into intertidal
(the shore between high and low tide lines) , subtidal (the
bottom below the low tide line), and pelagic (open water)
habitats. The most definite effect of existing Metro dis-
charges found to date on the biota of Puget Sound is a trend
toward higher lead and mercury concentrations in mussels
and clams near the West Point outfall; levels found were
within toxicity guidelines (Schell, et al., 1977). Harman,
Stober, et al. (1977) found no statistically significant
effects of the West Point discharge on benthic invertebrate
distribution, but their data do suggest some subtle changes
in species composition. Campbell, et al. (1977) found no
changes in phytoplankton production or standing stock due
to the West Point discharge. The West Point discharge may
lower the growth rate of subtidal kelp beds nearby, due possibly
to suspended solids from the discharge causing lower light
penetration (Metro 301h waiver application).
Miller, et al. (1977) found differences in species com-
position and abundance in the nearshore fish fauna between
areas off West Point, Alki Point, and Point Pulley. They
attributed the differences to habitat differences (eelgrass)
not related to wastewater outfalls. In their study of demersal
(bottom) fishes, high incidences of Dover sole, rex sole,
ratfish and quillback rockfish near West Point were noted
as possible beneficial effects of the West Point discharge.
Acoustical (sonar) tracking surveys indicated no effect of
the West Point outfall on pelagic fish distribution of abun-
dance (Duxbury, 1976). The acute toxicity of the West Point
primary effluent (LC50) ranged from 15.4 percent effluent
in 96 hours for shiner perch to 50 percent effluent in 120
hours for shore crabs (Stober, et al., 1977).
185
-------
Green/Duwamish River. The fish resources of the Green/
Duwamish River system are of particular importance for this
EIS. Chinook, coho and steelhead runs of the Green River
system are among the largest in the Puget Sound region. Most
of the steelhead and coho are of hatchery origin, whereas the
Chinook run is the second largest native run in Puget Sound,
even though significant numbers of chinook are also of
hatchery origin. Other less prevalent anadromous fish found
in the Green River system include cutthroat trout, Dolly
Varden char, chum salmon and pink salmon. The Muckleshoot
Indian tribe propagates a small hatchery run of chum salmon
(U. S. Fish and Wildlife Service, 1980).
The Department of Fisheries estimates the value of the
approximately 220,000 salmon provided by the Green River
system to sport and commercial fisheries at $4.4 million.
Capital value of WDF hatchery facilities in the watershed
is $4 million. The economic value of the Green River steel-
head fishery was estimated to be $2-$3 million in 1976 (see
Appendix C), and the Northwest Salmon and Steelhead Council
estimates the value has tripled since then. Thus, total
annual Green/Duwamish River fishery value is over $10 million.
In addition, significant public expenditures are being made
to operate and maintain the fish hatcheries in the system
and to implement watershed improvement projects that maintain
or enhance fisheries.
The river and estuary below the Renton plant discharge
is a migratory route for anadromous species. Spawning habitats
do not occur near or below the Renton outfall. The estuary
may also be of importance as a rearing habitat for juvenile
chinook salmon. Use of estuaries by anadromous salmonids is
a relatively unresearched field. Myers (1980) found that
chinook salmon use the Yaquina Bay, Oregon estuary for rearing.
Although water quality standards violations have occurred,
no obvious effects on fish or other biota in the lower Green/
Duwamish River directly attributable to the Renton discharge
have been recorded at effluent discharge levels to date.
Matsuda and Domenowske (1971) found that fish avoided areas in
the estuary where DO approached 1 mg/1 in the mid-1960s, but
the low DO was due mainly to sources that have since been
controlled. Low DO concentrations in summer are now about
4 mg/1, which is marginal for survival of salmonids.
Fujioka (1970) found that at DO levels as low as 3 mg/1,
adult chinook salmon were still able to migrate through the
Duwamish estuary. He did find a positive correlation between
the amount of fall precipitation and the percentage of fish
tagged in the estuary that make it to the Green River Hatchery.
This may be an indication that low DO concentrations in the
estuary affect the survival of fish upstream.
186
-------
Buckley and Matsuda (1973) found that nondechlorinated
Renton effluent was toxic (96-hour LC50) to fingerling coho
salmon at 29 percent effluent, with a residual chlorine
concentration of 0.20 mg/1. With chlorine removed, no
mortalities occurred with effluent concentrations as high as
100 percent. Low pH levels in this study prevented un-ionized
ammonia from contributing to toxicity.
Impacts of Alternatives A-3/A-5. In the discussion
below Alternatives A-3/A-5 are assessed for potential impacts
on algal production, invertebrates, and fisheries.
Algal Production. Since nitrogen is limiting to algal
growth for brief periods in some years in central Puget Sound,
effluent discharge under Alternatives A-3/A-5 may have occa-
sional, local biostimulatory effects. These effects would
not be adverse, since algal standing crop levels in Puget
Sound do not presently approach nuisance levels. Small increases
in algal production may actually benefit Puget Sound fisheries
due to a greater primary food source. Growth of kelp may
be lowered near the discharge. However, effects would be
lower than at West Point, since suspended solids concentration
will be lower.
Invertebrates. Present discharges at West Point have
not created any measured significant adverse changes in
invertebrate distribution or abundance, though the data base
is weak. A Renton discharge to Puget Sound will probably
likewise have little effect on invertebrate occurrence.
Removal of the Renton discharge from the Green/Duwamish estuary
would alter the late summer and fall distribution of salt-
sensitive estuarine zooplankton species in response to the
altered salinity gradient.
A discharge to Puget Sound could cause small increases
in heavy metals accumulation in mussels and clams near the
outfall, as found near West Point. However, the heavy metals
in Renton effluent would be lower than in the West Point
effluent because there are fewer industrial sources in the
Renton service area, and because the Renton plant has a higher
degree of treatment.
Fisheries. The presence of a Renton effluent plume
in Puget Sound is not expected to adversely affect fish dis-
tribution, based on studies of fish near the West Point plume
(Duxbury, 1976). The diffuser may actually attract some
species, as does the West Point diffuser (Miller, et al.,
1977).
187
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Removal of Renton effluent from the Green/Duwamish River
would benefit fisheries in the river, as compared to Alter-
native A-l, because risks of process upset, and the contri-
bution of the Renton plant to temperature standards vio-
lations, would be removed. Potential for any subtle cumu-
lative effects, possibly caused by small concentrations of
toxic substances in the effluent, would also be removed.
Migration of adult salmonids and salmon migration and rearing
of juvenile salmonids would be safeguarded. Rearing of
juveniles in the estuary is of particular concern, since
the fish would be exposed to the effluent for a longer time
period than for migration.
Relatively little is known about the needs of salmonids
rearing in estuaries, as compared to their needs when rearing
in freshwater streams. Increasing attention is being focused
on estuaries. Of the salmonid species found in the Green/
Duwamish system, chinook salmon and chum salmon may be
especially dependent on the estuary for rearing due to their
relatively short rearing life stages in freshwater stream
areas.
Effluent removal from the river would decrease the fre-
quency of temperature standards violations in August (the
most frequent month of violations) by about 4 percent from
present conditions (a decrease from 81 percent to 77 percent),
or by about 12 percent compared to Alternative A-l at 99 MGD
(a decrease from 89 percent to 77 percent). The temperature
increases caused by the effluent over and above ambient,
with ambient in the vicinity of 18-20°C, are presently about
0.6-0.7°C, and would be about 1.2-1.4°C with 99 MGD of effluent
(Alternative A-l) (Metro, pers. comm.). It is not known
if this level of effect would actually alter the timing of
salmon migrations.
Impacts of Alternative A-l. In the discussion below,
Alternative A-l is assessed for potential impacts on algal
production, invertebrates, and fisheries, and relevant
improvements that would result from advanced wastewater treat-
ment under Alternative A-2 are noted.
Algal Production. Renton effluent nutrients probably do
not control algal growth in the Duwamish estuary (Welch, 1969;
Welch, et al., 1972; and Welch, 1980 in Welch and Trial, 1979).
Nutrients from the plant under Alternative A-l will therefore
probably have no effect on algal production in the Duwamish
estuary, and nutrient reijnoval under Alternative A-2 may be of
limited value. However, algal-nutrient relationships in the
estuary are not well understood.
-------
Invertebrates. There have been no studies of the effects
of the Renton discharge on invertebrates in the Green/Duwamish
estuary. It is not known whether continued discharge would
have any adverse effects on invertebrates.
Fisheries. Fish migration could be affected by Renton
effluent impacts on dissolved oxygen, temperature, and
toxicity. Each of these farters is reviewed below.
Present DO levels in the Duwamish estuary are as low
as 4 mg/1 in summer (Welch and Trial, 1979), a level which
can effectively block the upstream migration of adult salmonids.
The DO sag in the estuary has been attributed largely to
ammonia from the Renton plant (Yake, 1980). This would cease
to be a concern under Alternative A-l due to nitrification.
A second concern regarding the Renton discharge to the
Duwamish is high water temperatures blocking the upstream
migration of adult salmonids in late summer and early fall.
Temperature standards would be violated about 77 percent
of all days in August without a Renton discharge to the river,
but the discharge would increase the frequency of violations
to about 89 percent of all August days in the year 2000.
It is not known whether present delays in upstream migra-
tion of chinook salmon in late summer are caused by low DO
concentration, high temperature, or some other flow-related
factor. Therefore, the incremental thermal effects of discharge
to the Green/Duwamish River on migratory salmon cannot be
predicted at this time.
Effluent toxicity could also affect fish migration.
The main acute toxicity component of the Renton effluent
is residual chlorine. Despite dechlorination to 0.25 mg/1,
the Renton plant discharge results in chlorine levels as
high as 0.19 mg/1 in the immediate vicinity of the discharge,
and 0.07 mg/1 about 1 mile downstream (Bernhardt, 1980).
These concentrations approach levels toxic to fish. The
lethal (96-hour LC50) concentration to coho salmon fingerlings
of residual chlorine in the Renton effluent was found to be
0.20 mg/1 in 29 percent effluent (Buckley and Matsuda, 1973).
The reported value of 0.20 is actually a 48-hour LC50, since
no fish died after 48 hours in the tests.
Under Alternative A-l adverse effects on fish due to
chlorine toxicity may occur if more effective dechlorination
is not implemented. If residual chlorine continues to be
discharged in present concentrations, future river and effluent
flow conditions may result in "slugs" of effluent in the
river with chlorine concentrations of 0.20 mg/1 or above
in the immediate vicinity of the discharge. Metro is pre-
sently looking into ways to lower the residual chlorine con-
centration in the Renton effluent. Ammonia toxicity would
not be a long-term problem because nitrification would be
189
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in the Renton treatment train. However, ammonia would be
lethal to salmon during periods of high pH if the nitrifi-
cation process broke down.
High incidences of fin erosion and liver tumors have
been found in starry flounder and English sole in the Duwamish
estuary. The causes of these diseases are unknown. Fin
erosion diseases have been associated with areas of heavy
wastewater discharge in the ocean off southern California
and in the New York Bight (Miller, et al., 1977). In addition,
Metro studies (pers. comm.) have found that long-term (91-day)
exposure of coho salmon to 30% Renton effluent produced a
dysfunction of carbohydrate metabolism unrelated to chlorine
or ammonia; such effects could also occur to resident non-
anadromous fish living in the estuary.
Miller, et al. (1977) suggests that the diseases are
actually two manifestations of a single systemic disease
caused by one or more chemical contaminants, possibly PCBs.
The Renton discharge has not been associated with high levels
of PCBs. Continued discharge to the Green/Duwamish River
is not expected to contribute to adverse pathological effects
on fish.
If impacts on the Green/Duwamish fisheries do occur,
the effects may compound over a number of years to severely
reduce a portion of the fish stocks.
Impacts of Alternative B-l. The aquatic biology and
fisheries impacts of Alternative B-l would stem from water
quality impacts of the alternative. As previously discussed,
the Richmond Beach outfall is unlikely to create measurable
adverse water quality impacts in Puget Sound due to low flow
and the residential origin of the wastewater. Therefore,
no corresponding biological impacts in Puget Sound are
expected.
Impacts on aquatic organisms and fisheries in the Green/
Duwamish River under Alternative B-l would be similar in
kind to those previously described for Alternative A-l. Because
effluent flows to the river would be reduced under Alter-
native B-l, potential adverse biological impacts would be
less severe than under Alternative A-l.
Impacts of No-Project. Major adverse impacts on the
fishery of the Green/Duwamish River may occur if no project
is built and new sewer hook-ups are not restricted. The
effects would stem from the water quality impacts on the
river. Un-ionized ammonia would exceed levels toxic to coho
salmon during periods of high pH due to algal blooms. DO
levels would be far below levels necessary for diverse popula-
190
-------
tions of fish, especially salmon and steelhead. The continued
existence of the fishery would be threatened. The most severe
effects would occur during the low flow periods of summer and
early fall.
Mitigation Measures. This section presents mitigation
measures for the long-term water quality and biological impacts
of Metro's wastewater management alternatives. Mitigation
measures for short-term water quality impacts are discussed
in the following section.
Oceanographic and Biological Studies. Although the
preceding impact analysis concludesthat there is little
possibility that Renton plant discharge to Puget Sound
will adversely affect the sound's water quality or ecology,
additional scientific work is necessary to verify this con-
clusion and to design the outfall so as to minimize impacts
on the sound and its beaches. Additional detailed oceano-
graphic studies are proposed by Metro to determine optimal
outfall alignment, depth of discharge, and diffuser design
parameters, and to predict pLume locations, mixing, and
dilution. Metro has also proposed to undertake biological
studies to establish baseline data and monitor biological
responses once the outfall is in operation. These oceano-
graphic and biological studies, which are described in further
detail in the Wastewater Management Plan, are necessary to
more precisely predict and mitigate the impacts of Renton
plant discharge to Puget Sound. In particular, the oceano-
graphic studies should include determination of shoreward
travel times of surface currents during times of winter south-
westerly winds.
Monitoring. Metro will conduct an ongoing water quality
monitoring program in the vicinity of the outfall. If this
program or any other Puget Sound study finds evidence that
the discharge is producing significant adverse effects, there
are several actions Metro can take in response, such as ex-
tending the outfall, redesigning the diffuser, increasing
treatment levels, requiring stricter source controls or pre-
treatment, and foregoing additional treatment plant expansions.
Heavy Metal and Toxic Substances Impacts. Although
the contribution of heavy me!_als to Puget Sound from the
Renton plant will be small compared to other sources, control
of heavy metals and toxic substance discharges is desirable
because of the potential for long-term irreversible impacts.
Metro has adopted an industrial pretreatment program and
is currently pursuing a comprehensive program concerning heavy
metals and other toxic constituents in its wastewaters. The
toxicant study will identify toxic constituents and sources
within Metro's service areas, propose pretreatment alterna-
tives, propose centralized treatment alternatives, and research
the distribution, inputs and chemical and biological fates
of toxicants in Puget Sound.
191
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Chlorine Toxiaity. Chlorination and dechlorination
are the final steps o± wastewater treatment under Alterna-
tives A-3/A-5. Improvements are needed to the Renton plant's
chlorination system to prevent toxicity problems, and are
proposed as part of Alternatives A-3/A-5. Metro has proposed
near-term improvements in the chemical feed system to reduce
residual chlorine levels in Renton effluent. Once the tunnel
and outfall to Puget Sound is operational, it may be used
for chlorine contact. The Wastewater Management Plan
indicates chlorine doses can be reduced compared to present
practices because contact time will be increased; if the
contact time is long enough, chlorine residuals may decay,
thereby reducing or eliminating sulfur dioxide requirements
for neutralization.
Short-Term Water Quality and Aquatic Biology Impacts
During Project Design and Construction.
Impacts. Under any of the alternatives, short-term
deteriorations in Green/Duwamish River water quality will
occur between the present time and 1985, when the planned
additional facilities are on-line. The expected short-term
impacts, and mitigation measures for these impacts, are
discussed by Metro in its Wastewater Management Plan and
summarized here.
Metro projects that during the 1980-1985 construction
period, average wet weather flows will increase from 41 to
50 MGD, excluding the Redmond connection flows. If the
Redmond connection were brought on-line by 1985, 4 MGD
would be added.
As noted in the previous analysis of water quality im-
pacts, water quality standards in the Green/Duwamish River
downstream of the Renton discharge are being violated for
temperature, DO, ammonia and chlorine. Increased flows between
1980 and 1985 will increase the frequency and degree of these
violations (with the exception of chlorine, which is expected
to be brought down to acceptable levels in the near future).
In addition, the DOE recommendations for 20:1 effluent dilution
will continue to be exceeded.
The short-term deterioration in water quality would
probably cause adverse changes in the biology of the Green/
Duwamish River. No effects on fish or other biota directly
attributable to the Renton discharge have been measured at
current discharge volumes, but particular concerns exist
regarding Renton effluent impacts on ammonia toxicity and
DO, as they affect salmonid rearing and migration, other
fish species, and the river's ecology in general. Further
increases in ammonia and decreases in DO will create increased
risks that fisheries will be adversely affected.
192
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Mitigation Measures. Metro has identified several mea-
sures currently available to reduce BOD and SS levels during
periods of excessive flows. These measures are 1) storage
of excess flows in the Renton plant influent sewer, 2) "stress-
ing" of the secondary treatment process, 3) alum addition,
and 4) giving primary treatment to excess flows, and blending
the secondary effluent prior to discharge.
These measures, however, address neither the ammonia
toxicity problem nor the oxygen demand from the un-ionized
ammonia. Metro has identified two groups of mitigation mea-
sures for these problems: measures to be implemented, and
additional measures available. These mitigation measures
are listed in Table 6-8, which also presents Metro's evaluation
of the effectiveness and costs of each measure. Metro believes
that, although few of these measures alone can solve the
ammonia problem, combinations of these measures can adequately
protect fishery resources over the short term.
Resource Use
Energy Use
Each long-term alternative significantly increases energy
consumption for study area wastewater management, primarily
due to the treatment stage of each alternative. Other energy
uses are for sludge treatment, influent pumping stations,
effluent pumping (for marine discharges) and disposal (for
land application). The overall energy requirements of each
of the 15 initial alternatives are tabulated in Table 6-9.
Also shown are the energy requirements for treating each
million gallons of wastewater.
From Table 6-9 it appears that of the initial 15 alterna-
tives, Alternatives B-3, B-4, or B-5 offer the least energy
consumption, using about 66,000,000 Kwh per year, or 1,830
Kwh/mg, primarily due to the lower degree of treatment
required compared to nitrification and AWT alternatives.
Insufficient information is available to determine which
of the three is the most energy efficient. The highest energy
requirement (4,070 Kwh/mg) is for AWT and discharge to the
Duwamish River (Alternative A-2); this high energy cost can
be attributed to the high degree of treatment and the high
energy requirements for recalcination of lime sludge and
regeneration of activated carbon.
Of the four final alternatives, Alternative B-l has
the lowest energy requirement, 2,080 Kwh/mg. Alternative A-l
has the highest energy requirement, 2,710 Kwh/mg. The no-
project alternative would not change energy consumption above
the present rate of increase.
193
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Table 6-8. Interim Measures to Reduce Ammonia Loading to the Duwamish River
Potential Reduction Capital
of Current Couts
VD
Measures to he Imn! i_.mnnt.'d
1)
2)
3)
Fast Track Implementa-
tion of Plant Expansion
Diversion of Flow via
Sludge Force Mains
Reduced Summer Flushing
Ajrunonia Load
high
slight
slight
to Mv-ti
high
slight
none
Incremental 0/M
Costs to Metro Coifunonta
4) Industrial Source Control high
Additional Measures Available
1) Interim Nitrification with moderate
Existing Facilities
2) Construct Special Nitri-
fication Facilities
a) A.ijv.onia Stripping high
b) Roughing Filters high
c) llreakpoint Chlorination hLgh
3) t'se of Kent/Auburn Lngoons mo-lcrate
<) Diversion of Flow via moderate
Ri Vi-rvon/Ronton Pump
St.it ion
moderate
high
h igh
high
moJorjtc
high
moderate
slight
si ight
none
high
high
hiyh
high
moderate
Implementation of this alternative would
require 3 to 4 years.
Modifications currently being made to implement
this diversion.
Requires impl eraentat ion of some form of c-ffluent
diversion to achieve a slight amount of ammonia
removal.
Some industrial discharge permits have been re-
negotiated to eliminate ammonia discharges.
This alternative could seriously impact treat-
ment plant operations thus jeopardizing
overall effluent quality.
High capital cost alternatives which could com-
pletely remove ammonia in the effluent.
(Iso of lliie alternative in dependent upon the
aval l.ibili ty of the existing Kent ami Auburn
1 acjoons.
High capital cost project which could allow up
to 10 imjd to be diverted to West i'oint. Would
tak*> 2 years to implement
5) Diversion of Effluent high
for Land Disposal
6) Local Agency Infiltration slight
Control
7) Water Conservation slight
B) Interim River Flow hiyh
Auyr.entation
9) Fisheries Resource Protec- none
tion
10) Seuer .Moratorium none
11) Eliir.lr.ati: Scpr.ayn nijipossl slight
SOURCE: Metro, 1981.
high
high
unknown
moderate moderate
moderate moderate
Large amount of land area required near the
treatment facility may not be available.
Requires implementation of some form of effluent
diversion to achieve a slight amount of ammonia
rcn.oval.
Requires implementation of some form of effluent
diversion to achieve a slight amount of aiunonia
removal.
The success of this alternative ia dependent
upon the cooperation of the U.S. Army Corps of
engineers in operating the Howard Hanson Dam,
and the availability of stored water.
Requires the cooperation of the Department of
fisheries.
The effectiveness of this alternative is ques-
tionable. If implemented its impact would be In
the reduction of future anunoriia levels.
This measure significantly diirupi-a curri-nt
sorL-igu .Kcposal practices yoc only reduces
anjnonia loading to the \i\ant. \jy I.3».
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Table 6-9. Estimated Energy Requirements
for Proposed Alternatives
Alternative
Basic Program
A-l
B-l
C-l
Basic Program and Nutrient
Removal at Renton
A-2
B-2
C-2
Basic Program-Renton
discharge at Point Pulley
A-3
B-3
C-3
1,000 Kwh/yr*
98,000
75,000
76,300
137,000
104,000
105,300
87,000
66,000
67,300
Kwh/mg*
2710
2080
2080
3790
2880
2870
2410
1830
1830
Basic Program-Renton
discharge in Elliott Bay
A-4
B-4
C-4
Basic Program-Renton
discharge at Alki Point
A-5
B-5
C-5
87,000
66,000
67,300
89,000
68,000
69,000
2410
1830
1830
2460
1880
1880
^Current energy use at Renton plant is approximately 24,000,000 Kwh/yr (see Ficnirv 2-12)
**mg = million gallons '
Source: Metro, 1980h.
195
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Energy cost is expected to be the highest portion of
the O&M costs, and since energy use is high for each alterna-
tive, energy efficiency is expected to be a critical design
criterion. Maximum use of digester gas recovery is to be pursued
in the alternative selected, and energy-efficient processes
and equipment are anticipated for selection during the design
of the selected project.
Chemical Use
The evaluation of long-term alternatives should consider
the required use of chemicals. Especially important are
lime and activated carbon, which both require regeneration.
As energy costs rise, so will the cost of using these chemicals.
The use and recalcination of lime not only add a cost for
direct chemical purchases, but also greatly increases the
on-site energy use. Activated carbon also creates high costs
for energy because of the periodic regeneration requirements.
Therefore, alternatives which use lime and activated carbon
are substantiallly more energy-intensive and expensive than
other alternatives, other things being equal.
Table 6-10 displays the chemical requirements for each
of the 15 initial alternatives. Lime, methanol and activated
carbon are only used in the AWT proposals (Alternatives A-2,
B-2, C-2) which discharge to the Duwamish River; the AWT
alternatives require more chemical use than any of the other
proposed alternatives. The marine discharge alternatives
do not require dechlorination for discharge and therefore
require the least amount of chemicals. The alternatives
which have nitrification and discharge to the Green/Duwamish
River require sulfur dioxide to dechlorinate the effluent.
All alternatives require chlorine to disinfect the effluent
before disposal. The six small satellite plants, under
Alternatives C-l - C-15, require more chlorine because the
risk of human contact is greater. Ferric chloride is used
to enhance dewatering of solids processed at all proposed
plants.
If the AWT alternatives were to be selected, careful
consideration should be given to large bulk purchases (allowing
lower per unit cost) and energy efficient methods of lime
and activated carbon treatment. Methanol cost may not rise
as fast as the cost of other chemicals because of the fuel
potential and possible greater future supplies of methanol.
Of the four final alternatives, Alternatives A-3/A-5
require the least amount of chemicals. Therefore, the risk
of cost escalation due to increased energy costs and chemical
use is the lowest.
196
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Table 6-10.
Estimated Chemical Requirements
(tons per year)
Alternative
Basic Program
A-l
B-l
C-l
Basic Program and
Nutrient Removal
at Renton
A-2
B-2
C-2
Basic Prog rain-Ren ton
discharge in
Puget Sound
A-3, 4, 5
B-3 4, 5
03, 4, 5
Methanol'
Activated-* Sulfur^ Ferric
Carbon Chlorine^ Dioxide Chloride
760
550
580
240
170
170
872
77J
77]
13,550
9,860
9,860
6,870
4,990
4,9^0
540
390
390
760
550
580
240
171
171
64 (J
568
568
760
550
580
79L
859
85')
Assumptions
1. 750 pounds lime/million gallon:; (Ib/mg)
2. 330 Ib methanol/mg
3. 30 Ib activated carbon/mg (make-up)
4. 42 Ib chlorine/mg for discharge to water
83 Ib chlorine/mg for discharge to land
5. 13 Ib sulfur dioxide /ay for discharge tc
sh River only
SOURCE: Brown and Caldwell, pers. comm., 1980
197
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Mitigation Measures
In the design and operation of the selected alternative
efforts should be made to minimize energy and resource use.
This is an important principle, one which Metro is committed
to, from both resource conservation and cost standpoints.
Growth-Related Impacts Resulting from
Staging of Alternatives
Background
Most of the growth-related impacts of the long-term
wastewater management alternatives for the study area are
common to all the alternatives, and these impacts are assessed
in Chapter 7 of the EIS. However, each of the alternatives
has one or more nonmodular facilities; the sizing and staging
of these nonmodular facilities has important growth implica-
tions .
As a general rule, in order to minimize potential growth-
inducing or growth-inhibiting effects of wastewater facilities,
it is desirable to design the facilities so that they can
be added to in modules, allowing flexibility in response
to changes in population projections or land use plans. However,
some facilities are considered nonmodular, because adding
additional modules of capacity is not cost-effective or creates
major adverse construction impacts.
Interceptor sewers are a common example of a nonmodular
facility. Trade-offs always exist in the sizing of interceptors
between providing a large initial excess capacity, which
may be cost-effective and minimize construction disruptions,
and providing a smaller initial excess capacity, which creates
less risk of growth inducement. EPA cost-effectiveness analysis
guidelines (40 CFR, Part 35, Subpart E) provide that federally-
funded interceptor sewers should not be designed for a staging
period of longer than 20 years, unless the long-term growth
projections are consistent with planned land uses in 208
plans and the longer staging period would reduce both primary
and secondary environmental impacts. Although these guidelines
do not apply if the interceptor is locally-funded, they do
indicate EPA's concerns related to adverse impacts of inter-
ceptor staging periods longer than 20 years.
In the analysis that follows, the flexibility of each
long-term alternative is assessed by considering the extent
to which it relies on nonmodular facilities. In addition,
for Alternatives A-3/A-5, potential impacts of sizing the
Renton outfall tunnel and Redmond connection for 50-year
flows are discussed.
198
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Impacts of Alternatives A-3/A-5
Overall Flexibility. Because Alternatives A-3/A-5 involve
the construction of several nonmodular facilities (Redmond
connection, North Creek/Hollywood connection, and Renton
outfall tunnel), they are probably the least flexible of
any of the long-term alternatives being considered, other
than the no-project alternative.
Potential Impacts oC_t_he_ Ro;iLon Outfall Tunnel and
Redmond Connection. The method for sizing and staging com-
ponents of Alternatives A-3/A-5 is described in Section D6j
of the companion document to the Wastewater Management Plan.
The basic approach used was to select the staging period
which has the least cost present worth. Based on this
approach, it was decided to expand the Renton treatment
plant into two phases to meet flows projected for the year
2000, but to construct the Renton outfall tunnel and Redmond
connection in single stages to meet projected year 2030 flows.
Peak flow projections used to size the Renton outfall
tunnel and Redmond connection are shown in Table 6-11. Methods
for developing the year 2030 flows derive from the long-
term population projections in Metro's 1958 comprehensive
plan.
Constructing the Renton outfall tunnel and Redmond con-
nection in single, 50-year stages results in the least present
worth cost, delays the potentially major impacts of constructing
new or parallel facilities, and reduces the risks of running
out of capacity if PSCOG's population projections err on
the low side. This approach also has several disadvantages.
First, projections beyond 20 years, such as those underlying
the calculations of year 2030 peak flows, are not recognized
by land use planning agencies or PSCOG; this means that the
Redmond connection and tunnel/outfall arc being planned in
advance of land use planning for the study area. Second,
if the Metro year 2030 population projections err on the
high side, unneeded capacity would be funded and built. Third,
unless a "bottleneck" exists elsewhere in the sewerage system,
capacity will be available for 20-year flows in excess of
those based on the PSCOG population projections. The Renton
treatment plant capacity acts as a bottleneck for the Renton
outfall tunnel, but it does not appear that such a bottleneck
exists for the Redmond connection, other than the York and
Totem Lake pump stations. If Redmond connection flows were
to exceed the PSCOG-based flow projections, potential treatment
plant capacity problems could result.
199
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Table 6-11.
Long-Term Peak Flow Projections Used to Size
Renton Outfall Tunnel and
Redmond Connection
(MGD)
NJ
O
O
Facility
Renton Outfall Tunnel3
Redmond Connection
- North Lake Sammamish Service Area
- North Lake Washington Service Area
1980
144
16.9
8.2
8.7
2000
238
40.4
17.7
22.7
2030
325
75.0
38.0
37.0
SOURCE: Metro, 1980h.
'SOURCE: Metro, 1980h.
-------
Under the recommended program in Metro's final plan,
the decision whether to construct the Redmond connection
would be deferred, but the tunnel/outfall would still be
designed to accommodate 50-year flows from the sewered
portions of the entire study area as in Alternatives A-3/A-5.
If flows from the north part of the study area are not diverted
to the Renton plant in the future, capacity considerably
in excess of 50-year needs would exist in the tunnel/outfall.
Impacts of Alternative A-l
This alternative offers slightly more flexibility than
Alternatives A-3/A-5 because it does not require construction
of an outfall and tunnel to the sound. The Redmond and North
Creek/Hollywood connection would still be required.
Impacts of Alternative B-l
This alternative is more flexible than Alternatives A-3/A-5
because construction of the Kenmore treatment plant eliminates
the need for the Redmond and North Creek/Hollywood connection.
The Kenmore treatment plant is more capable of responding
to changes in population projections or land use plans in
the north part of the study area than are the nonmodular
effluent lines; the Kenmore treatment plant is thus less
likely to be growth-inducing or growth-inhibiting. However,
a tunnel and outfall to Richmond Beach would be required
under this alternative, raising the same sorts of sizing
and staging concerns as presented by the Renton outfall
tunnel.
Impacts of No Project
The no-project alternative is less flexible than any
of the long-term alternatives being considered by Metro,
because it is the least responsive to future growth. By
not expanding the Renton plant, capacity would not be available
to serve planned-for growth within the study area.
Mitigation Measures
The main adverse impacts identified in this section
are the disadvantages associated with sizing and staging
the Renton outfall tunnel and Redmond connection for 50-
year peak flows. The relationship between staging of sewerage
capacity and growth has been recognized in existing mitigation
measures such as King County's Sewerage General Plan and
Metro Resolution 2933 (see Chapter 7). Two additional miti-
gation measures are available.
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Reduce Staging Period. The staging period for the Renton
tunnel outfall and the Redmond connection could be reduced
from 50 years to 40 years or 20 years. The disadvantages
of this measure are that the potentially major construction
impacts of parallel facilities would occur sooner, that a
shorter staging period would have a higher present worth
cost, and that capacity limits may be reached sooner than expected
if PSCOG's population projections err on the low side.
Base 50-Year Flow Projections on Land Use Plans or PSCOG
Forecasts. Metro, local governments, and PSCOG could work
together to arrive at 50-year population and peak flow pro-
jections that are more firmly based on current land use
policies. For example, PSCOG in 1978 developed very long-
term (to the year 2075) population projections for Seattle
water planning (Seattle Water Department, 1980). Perhaps
these projections could be disaggregated by drainage basin
for 50-year flow projections. To the extent this is possible,
the potential growth-inducing impacts of the outfall tunnel and
Redmond connection would be reduced. In its Wastewater
Management Plan, Metro suggests that local agencies review the
50-year flow projections; perhaps a more formalized process of
local agency and PSCOG input to the 50-year projections could be
implemented.
Recreation Opportunities
Pursuant to EPA's facilities planning requirements,
Metro has prepared a comprehensive assessment of recreation
opportunities associated with wastewater treatment alterna-
tives; this assessment appears in Section J of the companion
document to the Wastewater Management Plan (Metro,
1980h). Based on this assessment, Metro has identified several
recreation opportunities for possible eventual implementation.
These opportunities, which are listed in Table 6-12, apply
largely to the preferred program, although some could be
implemented with Alternative A-l or B-l as well; recreation
opportunities additional to those shown in Table 6-12 would
be created by construction of the Kenmore treatment plant
and the tunnel/outfall to Richmond Beach under Alternative B-l.
All the long-term wastewater management alternatives
create the potential for additional recreation opportunities
within the study area. Recreation benefits include progress
toward the Clean Water Act's "fishable-swimmable" water
quality goal, in addition to the opportunities shown in
Table 6-12.
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Table 6-12. Potential Recreation Opportunities Provided by Long-Term Alternatives
Preferred Alternative Alternative
Recreation Opportunity Program A-l B-l No-Project
Interconnection of the Tolt Pipeline Trail, x x
Sammamish River Trail, and the Bridle Crest
Trail via an adjacent linkage of a trail
system provided through the North Creek/
Hollywood connection and Redmond connection.
These trail linkages provide direct and
indirect access to the water bodies of Totem
Lake, Sammamish River and Lake Sammamish.
Through Renton treatment plant expansion, x x x
provisions are possible for a public infor-
mation network located throughout the
Q plant components as an environmental educa-
^ tion feature.
Potential trail access to the Green/Duwamish x
River adjacent to the existing Renton treat-
ment plant site, with linkage to the Inter-
urban Trail System and Fort Dent Athletic
Center.
Potential design features for proposed pump x
stations to include provisions for multiple
use, e.g., designing pump stations to include
an observation platform.
Mitigation of disruption to existing park x
facilities by integrating existing park
arrenities with a potential trail system
provided by outfall lines.
Additional recreation opportunities would also be created by construction of the Kenmore treatment plant and the
tunnel/outfall to Richmond Beach.
SOURCE: Metro, 1980h.
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Metro (1980h) notes that the recreation opportunities
listed in Table 6-12 have the potential for eventual imple-
mentation, depending on precise project definitions, site
locations, and alignments. Metro recommends continued
coordination with EPA, the Heritage Conservation and Recrea-
tion Service, the King County Parks Department, the Seattle
Parks and Recreation Department, and other local parks and
recreation agencies, in order to realize the recreation oppor-
tunities identified as part of wastewater management planning.
It should be noted that several of the alternative tunnel/
outfall alignments will have short-term adverse impacts on
park use. For example, the recommended program would disrupt
use of Seahurst Park during the construction period. Long-term
impacts of the tunnel/outfall on Seahurst Park are not expected
to be significant (see Chapter 5).
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Chapter 7
SECONDARY IMPACTS COMMON TO ALL ALTERNATIVES
Introduction
This chapter assesses the growth-related secondary
environmental impacts common to all long-term wastewater
management alternatives considered by Metro. These impacts
derive from the common population and land use projections
used to project wastewater flows for all the alternatives.
Growth-related impacts are of major importance for this EIS,
since the Lake Washington/Green River Basins study area
represents the major growth area for metropolitan Seattle
over the next 20 years.
EPA policies require the agency to consider the secondary
environmental impacts of wastewater projects receiving federal
construction grants. These secondary impacts are primarily
caused by the growth which expanded wastewater facilities are
typically constructed to accommodate. The secondary impacts
of a project may often be more significant than the project's
direct impacts.
Because Metro has relied on local land use policies
to designate the sewer service area, and on PSCOG population
projections to project wastewater flows, the proposed waste-
water system improvements will not "cause" the growth projected
by other agencies, but rather will assist its accommodation.
Although neither Metro nor EPA is institutionally "responsible"
for growth and its accompanying secondary impacts within
the study area, the philosophy that EISs are full disclosure
documents dictates that such secondary impacts be examined
in this EIS, and that mitigation measures be identified for
EPA, Metro, or other public agencies when appropriate. This
is particularly important in the case of air quality, agri-
cultural land, wetlands, floodplains, and cultural resources
impacts, for which EPA has developed explicit policies to
mitigate adverse secondary impacts. Those measures identified
for Metro may be the basis for grant conditions.
Relation of Wastewater Alternatives to Growth and Secondary
Impacts
Local Recognition of Relationship Between Sewerage
Availability and Growth. The important relationship between
sewerage availability and growth has been formally recognized
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by King County's Sewerage General Plan and General Development
Guide (first draft) policies, and by Metro's Resultion 2933.
(It should be noted that the General Development Guide [first
draft] is currently being revised.) The King County Sewerage
General Plan identifies local service areas (the only areas
eligible to receive sewerage service), and establishes a local
service area amendment process to assure consistency of sewer-
ing decisions with the county's growth policies. The county's
General Development Guide (first draft) has development
policies recommending that subdivisions with densities of
three dwelling units per acre or more be served by sanitary
sewers; these policies effectively limit development in areas
without available centralized sewerage service to densities
of less than three dwelling units per acre.
Metro, in its Resolution 2933, requires affected local
agencies to certify that trunk or interceptor sewers and
sewer hook-ups are consistent with applicable local land use
plans before it will construct the sewer or allow connection
to the Metro system. Through this resolution Metro is limited
to constructing only those sewers which are consistent with
local land use policies.
Growth and Secondary Impacts of a No-Project Alternative.
Technically, the most accurate method for assessing the secondary
impacts of a wastewater treatment expansion project is to
compare the impacts of growth patterns, in the absence of
the project, with those that would occur if the project is
implemented. Unfortunately, it is not possible to follow
this procedure in this EIS because PSCOG's regional growth
projections assume major increases in sewered population,
thereby assuming that necessary wastewater treatment capacity
will be available in the future. No regional growth projection
exists which assumes no further increases in sewered population
within the study area, and the generation of such a projection
is a very complex process beyond the scope of this EIS.
In the absence of a sewerage-constrained growth projection,
this EIS assumes that since expanded wastewater treatment
facilities will play some role in accommodating the population
growth projected by PSCOG, it is appropriate to examine the
environmental impacts of the PSCOG growth projections and
consider these as the secondary impacts of Metro's Wastewater
Management Plan. It is possible, however, to make some general-
izations related to the growth impacts of a no-project alternative
Lack of expanded wastewater treatment capacity would be unlikely
to affect the Puget Sound regional growth rate, which is
largely determined by birth rates, death rates, and net in-
migration (the latter strongly influenced by job opportunities
and lifestyle preferences). However, lack of sufficient
wastewater treatment capacity could have major effects on
the distribution of new development, by (1) encouraging
206
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development within other portions of the Puget Sound region
with adequate wastewater treatment capacity, and (2) encour-
aging lower density development within the study area more
compatible with the use of on-site systems, which would
require additional acres to be urbanized.
Growth and Secondary Impacts of the Recommended Program
Although this chapter assesses the secondary impacts
of projected growth within the entire study area, Metro's
recommended program calls for the expanded 72 MGD Renton
plant to provide service to only the south part of the study
area currently tributary to the Renton plant. Sewered areas
currently tributary to the West Point treatment plant would
continue to be served by that plant unless future planning
decisions call for diversion of these flows to the Renton
plant via the Redmond connection and North Creek/Hollywood
connections, as envisioned in Alternative A-3. The analysis
in this chapter nevertheless considers secondary impacts
throughout the study area because a possible consequence
of the recommended program would be the eventual treatment
of flows from the north part of the study area at the Renton
plant.
Assumptions for Secondary Impact Assessment
Several assumptions have been made in preparing the
following analysis of growth-related secondary impacts.
o Availability of expanded treatment plant capacity
within the study area will assist in accommodating
additional population growth.
o Availability of expanded treatment plant capacity is
only one of many factors (such as employment growth,
market forces, lifestyle preferences, local land use
policies, and infrastructure decisions) that together
operate to influence growth patterns.
o The population growth and land use changes that will
occur in the study area are those projected by PSCOG
in its "policy" projection.
o The adverse secondary impacts of growth have been
recognized by responsible agencies having jurisdiction
within the study area; these agencies have developed
plans, policies and regulations to mitigate such impacts,
and the effectiveness of these measures depends on their
implementation.
207
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o Sewer service will be provided outside of the initial
sewer service area as a result of incremental local
service area changes after 6 to 10 years.
Because of this last assumption, the assessment of secondary
impacts is not limited to the identified sewer service area,
but also takes into account growth impacts outside the service
area but within the Wastewater Management Plan study area.
Although the nonsewer area will generally not be served within
the next 6-10 years, amendments to the King County Sewerage
General Plan and future Metro interceptor sewer decisions
will eventually expand the service area for the Renton plant
beyond the present boundary. Expansion beyond the current
sewer service area can occur before all projected sewered
population occurs within the current service area. This
would have the effect of increasing the study area sewered
population beyond that projected by PSCOG, thereby accelerating
the rate at which capacity is used at the Renton plant.
Future EPA decisions related to the Renton sewerage
system may involve incremental expansion of the current service
area boundary. It is therefore important that the secondary
impact analysis in the EIS examine the impacts of growth
throughout the study area in a regional, comprehensive manner.
With this approach, the EIS can serve as the basis for assess-
ment of the cumulative impacts of future sewerage projects
tributary to the Renton plant.
Contents of Chapter
The next section of this chapter describes and assesses
the PSCOG population forecasts which underly the Metro
Wastewater Management Plan. The remaining sections of the
chapter describe impacts and mitigation measures within the
following areas: air quality, surface water and biology,
groundwater, land use, public services, and public finance.
Description and Assessment of PSCOG's
Population Projection
Method
To project the geographic distribution of total popula-
tion, employment and land use change within the planning area,
PSCOG used a computer-assisted model called the Activity
Allocation Model (AAM). This model seeks to answer the ques-
tion, "What significant relationships can be found between
the 1960 census data set and the 1970 census data set which
208
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can be used to account for the changes in households and
employment which occurred over that 10-year interval?" It
formulates the answer in a series of ten simultaneous equations
which produce projected changes in the number of households
and number of employees in each defined district. Land use
changes are derived by applying density factors to projected
numbers of households and employees. The AAM operates in
10-year forecast increments, and policy assumptions and model
results are evaluated for each increment.
The model's ten equations require two types of inputs:
data inputs and policy inputs. The data inputs describe the
number and distribution of households in various income cate-
gories, the household density, the amount of employment in
various economic sectors, the relative location of employ-
ment opportunities (expressed as highway travel times), land
use for various economic activities and a "composite amenity
index". The policy inputs include travel time to future
housing and employment locations, water and sewer service
availability, the relative location of households in other
income categories and the amount of vacant land available.
PSCOG has derived two distributions of population, housing
and land use for the study area. One is a trends allocation,
which is characterized by the primary importance of market
demand in determining patterns of land use. For that alloca-
tion, only the limitations on development inherent in the
current regulatory context were imposed; they included zoning,
subdivision regulation, land costs, availability of services,
existing tax laws and the availability of funds to build
new infrastructure such as highways, sewers and water supply
systems. The other distribution is the policy allocation,
which is characterized by restrictions on the conversion
of land from rural to urban use. The policy allocation
therefore provided that only low density uses would be allowed
in unsewered areas, that decisions regarding sewer and water
line extensions would be made by local governments rather
than by sewer and water districts, and that sewer service
areas would be expanded only by small amounts by 1990. In
addition, it contained "a significant increase" in incentives
for infill and compact development.
Projected Population
PSCOG projects that population in King and Snohomish
Counties will increase from 1,575,000 in 1980 to 2,112,500
in the year 2000, an average annual growth rate of 1.5 per-
cent. The projection for the Renton 201 study area, which
includes portions of King, Snohomish and Pierce Counties,
varies between the policy allocation and the trends alloca-
tion. In the policy allocation, area population would grow
209
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from the 1980 level of 537,087 residents to a total of 805,248
residents, an average annual increase of 2.0 percent. This
growth would be concentrated in the western portions of the
study area, with the largest shares of the total increase
occurring in the North Lake Washington, Green River and East
Lake Washington basins. In the trends allocation, the popu-
lation of the study area would grow to a total of 858,450
residents, an average annual increase over 1980 of 2.4 per-
cent. This growth would spread out more completely over
the study area; the largest shares would locate in the Green
River, North Lake Sammamish and North Lake Washington basins.
The distribution of new population in the study area projected
under the two allocations is compared in Table 7-1.
Critique
The AAM used by PSCOG to develop its population projections
relies on trends observed between 1960 and 1970 to predict
changes that will occur in the future. It distills the
observed trends into a series of equations that describe
changes in population and employment factors as well as land
use and transportation conditions and policies.
This approach is subject to question on several grounds,
some of which were noted in a PSCOG information item dated
March 9, 1977. First, because it relies on data from 1960
and 1970, it cannot account for influences on urban form
not present during that decade, such as gasoline and housing
prices and interest rates, that are significantly higher
relative to real income than they were during that period.
Second, because the model predicts on the basis of
observed trends rather than the underlying reasons for those
trends, it is susceptible to the statistical problem known
as covariance; this problem occurs when variation in one
condition appears to cause variation in a second, but in
reality the variation in both results from the activity of
a third factor. Finally, problems could result from the
availability of local data and the consistency of data
measurement, a factor of particular importance in land use
information.
The accuracy of any forecast, regardless of the method
or model used to develop it, may be expected to diminish
as its distance into the future increases because there may
be influences on development patterns that could not be fore-
seen or incorporated into the forecasting process. Examples
of such influences are changes in technology, changes in
family structures, changes in economic conditions and changes
in government policies. These factors may affect both the
210
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Table 7-1
PROJECTED POPULATION INCREASE BY DRAINAGE BASIN,
RENTON STUDY AREA, 1980-2000
Policy Allocation
Trends Allocation
Basin
North Lake Washington
North Lake Sammamish
East Lake Washington
South Lake Washington
South Lake Sammamish
Green River
White River
Mercer Island
TOTAL
1980
99,611
47,140
121,142
63,601
38,024
133,075
13,804
20,690
537,087
2000
167,702
81,312
180,694
77,158
51,863
193,877
29,244
23,398
805,248
Increase
68,091
34,172
59,552
13,557
13,839
60,802
15,440
2,708 '
268,161
% of
Study
Area
Increase
25
13
22
5
5
23
6
1
100
2000
153,650
101,972
151,258
105,217
59,340
230,053
33,299
23,661
858,450
Increase
54,039
54,832
30,116
41,616
21,316
96,978
19,495
2,971
321,363
\ of
Study
Area
Increase
17
17
9
13
7
30
6
1
100
Source: Puget Sound Council of Governments
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overall level and type of development within a geographic
region and the distribution of that development among sub-
areas of that region.
A more detailed analysis and discussion of the demo-
graphic forecasts prepared by PSCOG may be found in
Appendix A of the EIS.
Comparison of PSCOG Forecast to Other Forecasts
EPA Grant Regulations Relating to Population Forecasts.
In 1978, EPA established regulations for population fore-
casts to be used in facilities planning. The forecasts are
to be based on state projections prepared for EPA by the
Bureau of Economic Analysis (BEA) of the Department of Com-
merce in 1977. BEA is the federal agency responsible for
most economic forecasting, and is known in particular for its
OBERS (Office of Business Economics/Economic Research Service)
series of forecasts, on which the projections prepared for EPA
were, in part, based.
EPA has determined that its funding decisions will be
based on BEA's state totals, which each state is required
to disaggregate to water quality planning areas. There are
two exceptions to the mandate to use the BEA projections:
(1) in the event either a state, or a water quality planning
area, had completed its own population forecast prior to
June 26, 1978, that forecast can be used instead of the BEA-
based projection if the state projection does not exceed
by more than 5 percent the BEA state total, and the regional
projection does not exceed by more than 10 percent the re-
gional total determined by disaggregating the BEA state pro-
jection; or (2) the BEA projection may be appealed to EPA in
Washington.
The Bureau of Economic Analysis (BEA) Projections. The
BEA approach is "top down", based on analysis of the national
economy and of each state's economy in relation to the nation
as a whole. For all states, including Washington, BEA developed
projections for 1980, 1985, 1990, and 2000. Because no adopted
Washington state forecast predates June 1978, these BEA pro-
jections would normally serve as the basis of EPA funding
decisions in the State of Washington.
Status of BEA Projections in the State of Washington.
The State of Washington Office of Financial Management (OFM)
had undertaken its own population forecasting at the time
BEA's work for EPA was proceeding, and in 1979 the state
published that forecast. Because the state's forecast
deviated sharply from the BEA projection (exceeding the BEA
212
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figures by about 20 percent) a resolution of the difference
was sought by EPA in order to make clear the basis on which
the agency's funding decisions in the State'of Washington
would rest.
After reviewing a request by OFM for acceptance of the
1979 state forecast in lieu of the BEA projection, EPA head-
quarters instead authorized interim use of a forecast based on
the BEA projection increased by 10 percent in the year 2000.
Table 7-2 presents a comparison of the forecasts mentioned
so far: the initial BEA projection, the adjusted BEA
projection authorized for EPA use in funding decisions, and
the OFM 1979 forecast rejected by EPA for funding purposes.
A fourth forecast presented in the table represents OFM's
most recent revised state forecast.
The four projections presented in Table 7-2 show a wide
range in year 2000 population levels. Only a small amount
of this difference is attributable to different 1980 bases;
most of it arises from differences in rates of growth. The
State of Washington forecast represents about 24 percent
more people in the state in the year 2000 than the 4,858,000
level acceptable to EPA.
There has been considerable discussion between EPA and
the state about the differences in their forecasts, and EPA
has indicated ^procedures for challenges to the projections
EPA has proposed to use for funding decisions. It is not
known whether the State of Washington plans further challenges,
nor is it yet known how the anticipated publication of new
OBERS state projections or the actual 1980 census enumeration
(when published) could affect the ultimate population figures
applied in EPA's funding decisions.
Multiplicity of County and Regional Forecasts. Disagree-
ment about the future population is not confined to state-
level projections. There is also lack of agreement about
regional forecasts. At the regional level, the disparity
is of concern not only because it affects funding levels
but also because it suggests contradictory guidance to the
regional wastewater agency, Metro. That is, Metro is
required to both use the allocations of state population
projections to regions in its wastewater facilities planning
according to state law, and to abide by regional planning
criteria according to the charter of the agency and according
to the Metro 208 plan. Where state and regional agencies
disagree on the future growth of the region, Metro cannot
follow both paths simultaneously. Table 7-3 compares the
most recent allocations for the Puget Sound region and King
County, including the DOE allocation of the EPA-approved
state population projection. Also shown is the proposed
revision to the PSCOG regional projection, which had not been
adopted as of late 1980.
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Table 7-2
WASHINGTON STATE POPULATION FORECASTS AND PROJECTIONS
(OOOs)
1980 1985 1990 2000
1. BEA 1977 Projection 3,738 3,908 4,076 4,417
for EPA
2. BEA Adjusted Projection
Approved for Interim 3,926 4,159 4,392 4,858
EPA Use in Funding
Decisions
3. OFM August 1979 449Q 4Q36 5345
Forecasts
4. OFM December 1979 4/619 5/09Q 6/Q24
Revised Forecasts
Sources:
1. U. S. Department of Commerce, Bureau of Economic Analysis: Population,
Personal Income and Earnings by State, Projections to 2000, October 1977.
2. U. S. Environmental Protection Agency, Region X, Craig Partridge, pers.
corm. , April 2, 1980.
3. Washington, State of, Office of Financial Management: Recommended
Washington State Population Forecasts for Use in Municipal Wastewater
Treatment Construction Grants Program, September 1979.
4. Washington, State of, Office of Financial Management: State and County
Population Forecasts by Age and Sex: 1980-2000 (Special Report No. 30),
January 1980.
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Table 7-3. Comparison of Regional and King County
Population Forecasts
(OOOs)
Area
Puget Sound
Region
Projection by 1980 1990 2000
PSCOG - 1977 2,137 2,570 2,974
PSCOG - Proposed 2,188 2,632 3,073
1980 revision
King County
OFM (8-79)
OFM (12-79)
DOE Allocation of
EPA Projection
PSCOG
2,190
2,210
1,235
PSCOG - Proposed
1980 revision
OFM (8-79)
OFM (12-79)
DOE Allocation of
EPA Projection
1,257
1,268
1,280
2,655
2,798
1,443
1,530
1,611
2,935
3,326
2,679
1,400 1,575
(Policy)
1,429 N.T.
(Trends)
1,679
1,707
1,928
1,551
N.T.: Not tabulated.
Sources:
1. Puget Sound Council of Governments, Mayor Beth Bland: Memorandum to
King Subregional Council regarding Forecasts, February 13, 1980.
2. Puget Sound Council of Governments, Tim Watterson: Memorandum to
PSCOG staff regarding regional population, employment, income
forecast revision.
3. Washington, State of, Office of Financial Management: 1979 Revision
of County Population Forecast for Washington State: 1980-2000 (Table
1), August 1, 1979. December 1979 forecasts from PSCOG memo cited in
(1) above.
4. Department of Ecology: Letter to EPA Region X, September 4, 1980.
215
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As shown by Table 7-3, for King County, the DOE alloca-
tion is similar to the PSCOG projection, whereas for the
Puget Sound region, the DOE allocation is significantly lower
than the PSCOG projection. This does not appear to be a
major problem, since most of Metro's study area is within
King County, where the projections generally agree. It should
be noted that the DOE allocation will apply only to grants
issued after January 1981, and that the allocations will
be revised after 1980 census data become available.
Secondary Air Quality Impacts
Background
Under Section 316 of the Clean Air Act Amendments of
1977, the EPA is authorized to withhold, condition, or restrict
any grant for construction of sewage treatment facilities
if the proposed project will accommodate a larger increase
in air pollutant emissions than provided for under the local
portion of the State Implementation Plan.
The Washington State Implementation Plan, which includes
the air quality management plan (AQMP) for the central Puget
Sound region, was conditionally approved by the EPA on June 5,
1980. Details of the Central Puget Sound AQMP, which is
a plan for attaining federal standards for ozone, carbon
monoxide, sulfur dioxide, and particulates, may be found
in Appendix B of this EIS.
Assessment of Impacts
To determine whether Metro's Wastewater Management Plan
will accommodate a larger increase in emissions than provided
for in the local AQMP, the population projections underlying
both plans are compared here. Although the AQMP region con-
sists of four counties (King, Pierce, Snohomish, and Kitsap),
only portions of the first three are within the wastewater
plan study area; therefore, Kitsap County has been excluded
from the comparison of population projections.
Emission forecasts for population-dependent source categories
were developed for the AQMP by utilizing the September 1978
PSCOG population projection. In contrast, the Lake Washington/
Green River Basins wastewater management plan is based on
PSCOG's 1979 population projection. As indicated in Table 7-4,
there is less than 1 percent difference between the September
1978 and May 1979 PSCOG population projections for the three
counties. This difference is not considered significant,
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Table 7-4. Comparison of September 1978 and
May 1979 PSCOG Population Forecasts
for the Three-County Puget
Sound Air Quality
Planning Region
County/PSCOG
Forecast Year
1980
Year
1990
Pierce
September 1978
May 1979
Difference
Percent Difference
Snbhomish
September 1978
May 1979
Difference
Percent Difference
King
September 1978
May 1979
Difference
Percent Difference
Three-County Total
September 1_978
May 1979
Difference
Percent Difference
405,870
414,998
9,128
2. 3
291,266
291,266
0
0
1 ,203,756
1,207,756
4,000
0. 3
1,900,892
1,914,020
13,128
0.7
4fJj, .',4o
516,092
16,744
3.4
361,418
375,076
13,658
3. 8
1
1,
378,111
367 ,440
10,671
-0.8
2,238,877
2,258,608
19,731
0. 9
217
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since emissions forecasts for population-dependent source
categories are based upon emission factors which exhibit
larger margins of error than 1 percent.
From the comparison in Table 7-4, it can be concluded
that the proposed plan is consistent with the Central Puget
Sound AQMP; a re-evaluation of consistency would be required
if either the local portion of the State Implementation Plan
or the facilities plan are amended to incorporate updated
population forecasts. Since the population projections used
in Metro's wastewater management plan are consistent with
those used in the AQMP, the secondary air quality impacts
of growth accommodated by the wastewater plan have been examined
in the AQMP.
It should be noted that population growth is only one
factor affecting ambient air quality. Some of the interrelation-
ships between growth and air quality are explored in a recent
PSCOG study (PSCOG, 1980).
Mitigation Measures for Air Quality Impacts
The AQMP air quality control measures act as mitigation
measures for the wastewater plan's secondary air quality
impacts; no additional mitigation measures are needed for
this EIS. The AQMP control measures are intended to attain
and maintain federal air quality standards in the central
Puget Sound basin.
Secondary Surface Water and Biological Impacts
This section describes the generalized secondary impacts
of study area population growth on surface water quality,
aquatic ecosystems, and terrestrial ecosystems. Details
regarding existing biological and water quality conditions
within the study area may be found in Appendix C of the EIS.
Secondary Surface Water Quality Impacts
Background. The many lakes and streams in the study
area generally have good chemical water quality, in terms
of conventional toxic or oxygen-depleting pollutants. The
main types of water quality problems in the study area are
generally high coliform bacteria levels caused by malfunc-
tioning septic tank systems, or by pet, livestock, or wild
animal wastes; and erosion and sedimentation caused by land
disturbance and impervious surfaces that accompany urbanization,
218
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Water Quality Impacts of Urban Runoff. The land use
changes that accompany population growth alter the runoff
characteristics of land. The general effect is to increase
the amount of immediate surface runoff for a given amount
of rainfall. Higher runoff rates are caused by impervious
surfaces (rooftops, driveways, streets) and other factors
such as decreased raindrop interception by vegetation and
lower moisture-retention capacity of disturbed soil.
Runoff coefficients (the ratio of runoff to rainfall)
chosen by Metro for use in runoff modeling studies (Buffo,
1979) illustrate the great effect urbanization can have.
The runoff coefficients for different land uses are as follows:
Industrial .95
Commercial . 90
High Density .60
(multifamily)
Medi Density .35
(multifamily)
Low Density .20
(single family)
Open Space - Rural .05
Agricultural .01
Forest .005
Urban runoff can cause adverse water quality impacts in streams
and lakes. Study area streams are probably most affected by
sedimentation caused by raindrop impact on disturbed soils,
increased runoff rates, and streambank erosion. Study area
lakes are probably most affected by nutrient enrichment,
primarily phosphorus.
Metro has developed suspended solids, phosphorus, and
lead loading rates for various land use types within the
study area (Buffo, 1979); similar loading rates for other
nonpoint source pollutants are not available. Table 7-5
presents some of these loading estimates and indicates the
great increases in nonpoint source pollutants that occur
with urban vs. nonurban uses, and with stable vs. unstable
(recently disturbed) sites.
219
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Table 7-5. Nonpoint Source Pollutant Loading Estimates for Land Use
Types in Locations near Kent, Washington
Industrial
Conrnercial
High Density
Multi family
KJ
to
0 Medium Density
Multifamily
Low Density
Single family
Open Space Rural
Agricultural -
Pasture
Agricultural -
Farming
Site
Characteristics
Stable
Unstable
Stable
Unstable
Stable
Unstable
Stable
Unstable
Stable
Unstable
Stable
Unstable
Stable
Stable
Total
Phosphorus
(Ib/acre/yr)
1.1
3.2
0.8
3.6
0.9
2.7
0.1
1.8
0.08
0.5
0.01
0.07
0.38
0.0002
Total Suspended Solids Lead
(Lb/acre/yr) (Lb/acre/yr)
356.3 0.98
1,500.4
161.4 1.4
921.6
369.3 0.2
421.9
31.2 0.1
286.8
8.2 0.2
93.8
1.4 0.001
1.5
— ~~
— —
Forest - Douglas-
fir
SOURCE: Buffo, 1979.
Stable
0.00002
-------
It should be noted that pollutant loading rates are only
a rough indication of potential nonpoint source water quality
impacts. Of greater importance are the actual effects of
nonpoint source pollutants on specific receiving waters. Such
an analysis can only be done by considering each water body
individually.
Metro has used the phosphorus loadings in Table 7-5
to estimate the phosphorus loading to Lake Washington under
future year 2000 conditions of increased urbanization
(Figure 7-1). Because the population and land use projections
used by Metro are similar to those used in this EIS, it can
be assumed that the phosphorus loading increase shown in
Figure 7-1 is similar to that which can be expected using
the current PSCOG projections.
Water Quality Impacts of On-Site Systems. One possible
significant impact of urbanization is nutrient impact to
lakes from septic tank seepage. For example, Davis, et al.
(1978) estimated that 14 percent of the annual phosphorus
loading to Lake Meridian was from the 65 active septic tanks
in the watershed, as compared to 3 percent from storm runoff
and inlet flow, and 16 percent from nonstorm runoff and ground-
water. Also, Metro is presently attempting to define the
role of septic tank seepage in Pine Lake in a special lake
restoration study.
Within the drainage of a particular lake, water quality
trade-offs can exist at the time that sewering decisions
are made. The potential for nutrient enrichment from septic
tanks must be balanced with the potential for nutrient enrich-
ment and sedimentation from the increased impervious acreage
that would occur if sewers are installed.
A more detailed analysis of on-site system problems
is presented in a later section of this chapter discussing
secondary groundwater impacts. Mitigation measures for
potential adverse water quality impacts caused by failing
on-site systems are also discussed in the groundwater impacts
section.
Secondary Impacts on Aquatic Biology and Fisheries
Background. The inland lakes and streams of the study
area are complex ecosystems that include a variety of fresh-
water and anadromous fishes, which are of economic, recrea-
tional, and cultural importance. Common anadromous fishes
in the study area include coho salmon, red salmon, chum salmon,
steelhead, and sea-run cutthroat trout.
221
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NJ
to
2.5 -
~ 2.0 -
Q
-------
Streams. The following discussions describe expected
effects of increased runoff or nonpoint source pollution
loadings on stream flora, invertebrates, and fish.
Flora. Increased algal and aquatic plant growths in
streams due to higher nutrient loadings may occur (this can
be counteracted by the scouring effects of higher storm peaks) .
The most likely areas for increased plant growth would be
backwater areas and the lower, slow-flowing reaches of streams.
The effects of increased plant growths in streams could be
adverse if biomass reaches levels that actually physically
choke the stream or cause dissolved oxygen depletion, or
if growth in rooted plants along stream margins slows stream
flows, causing increased sedimentation. Moderate increases
in plant growth could actually enhance invertebrate and fish
production.
Invertebrates. The data plotted on Figure 7-2 illustrate
how urbanization is affecting stream invertebrate communities
in the study area. This figure shows the average "percent
EPT" for stream invertebrate samples gathered in a subdrainage
basin as a function of the percentage of the subdrainage
basin that is urbanized. The percent EPT is the percent
of stream invertebrates in a sample that belongs to the insect
orders emphemeroptera (mayflies), plecoptera (stoneflies),
or trichoptera (caddisflies). These insect groups are generally
regarded as good fish food. Furthermore, these insect groups
are relatively intolerant of sediment or organic pollution,
as opposed to some forms of oligochaete worms and fly larvae.
Thus, the percent EPT is a "living index" of physical and
chemical stream quality.
Figure 7-2 is a scientific indication that urbanization
is having adverse impacts on stream habitat quality in the
study area. Sedimentation is probably the main factor causing
this general decline. The study area as a whole is currently
19 percent urbanized, which would result in an average EPT
index of 51 percent, according to the regression line. With
the study area 28 percent urbanized in the year 2000 (projected
in the PSCOG policy projection), the average EPT index would
be reduced to 45 percent, which is a significant reduction.
Fish, The hydrologic, water quality, invertebrate com-
munity, and other changes accompanying urbanization will
adversely affect stream salmonid (salmon and trout) popula-
tions through a variety of interacting pathways. Figure 7-3
illustrates some of these pathways. Increased runoff and
soil erosion from urbanization can induce flooding, stream-
bank erosion, scouring, stream channelization (a human response),
sedimentation, and adverse effects on stream invertebrates
and fishes. Among fishes, salmonids are particularly sensitive
to sedimentation and scouring because they bury their eggs
in stream gravels.
223
-------
100-
80-
3 SAMPLES/BASIN
~— y = 62.9 - 0.65X
r = 0. 71
r2 = 0.50
p< 0.05
NOTE: REGRESSION CALCULATIONS
EXCLUDED BASINS WITH 3
OR FEWER SAMPLES.
FIGURE 7-2. RELATIONSHIP BETWEEN URBANIZATION
AND CLEAN-WATER STREAM INSECTS (PERCENT
Ephemeroptera , Plecoptera , Trichoptera ) IN RENTON
STUDY AREA.
224
-------
LAND
SURFACE
1
I
URBANIZATION
! IMPERVIOUS
/ SURFACES
L I!
DEVEGETATION
RUNOFF RATE
V
FLOODING
STREAM
CHANNELIZATION
SCOURING
FISH HABITAT
VARIETY
DECREASES
POACHING^
SOIL POLLUTANTS
DISTURBANCE /
I
£>SOIL EROSION
OSTREAMBANK
EROSION
V
SEDIMENTATION
FISH EGG
MORTALITY
INVERTEBRATE
COMMUNITY
QUALITY
DECLINES
=> FISHERY
DECLINE
FIGURE 7-3. URBANIZATION IMPACTS ON
SALMONID FISHERY RESOURCES
225
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The relationship between the percentage urbanization
of a subdrainage basin and the degree of overall aquatic
habitat degradation in the basin's streams appears to be
direct as suggested by Figure 7-2, Therefore, one way to
analyze the impacts of future growth on fishery resources
is to simply look at the increase in urban acres within sub-
drainage basins.
Table 7-6 shows the increase in urban acres between
1980 and 2000 for subdrainage basins within the study area,
as projected in PSCOG's policy projection. Subdrainage basins
with percentage increases in urban acres in excess of 40
percent (the study area average) are considered "high growth"
for purposes of the EIS secondary impact analysis.
Of the subdrainage basins considered high growth,
Mill Creek, Swamp Creek, and North Creek have the greatest
potential for fishery declines due to urbanization because
of their dramatic increases in urban acreage (greater than
50 percent increase in urban acres between 1980 and 2000).
Evans Creek and the White River basin also show increases
in urban acres of greater than 50 percent, but these per-
centage increases are misleading because the number of urban
acres in 1980 is relatively small, and the basins will remain
relatively unurbanized through the year 2000.
By the year 2000 Swamp Creek is projected to become
55 percent urbanized, North Creek is projected to become
46 percent urbanized, and Mill Creek is projected to become
40 percent urbanized; present levels of urbanization for
these three basins are 35 percent, 30 percent, and 18 percent,
respectively- As the level of urbanization exceeds 40 percent,
natural reproduction contributing to the fisheries in the
subdrainages could be totally lost; for example, Juanita
Creek is presently 46 percent urbanized and its natural fishery
has been essentially eliminated. Fishery losses due to urbani-
zation will occur in other high growth subdrainage basins,
but probably not to the extent of Swamp Creek, North Creek,
and Mill Creek.
North Creek and Swamp Creek support primarily coho salmon;
in 1976 there were about 2,200 spawners in North Creek and
1,700 spawners in Swamp Creek (Metro, 1978c). Numerical
estimates are not available for Mill Creek. The coho runs
in Swamp Creek and North Creek have a net economic value
(1976 dollars) of about $102,000 annually, based on a catch/
escapement ratio of 2.0; a commercial harvest/sport harvest
ratio of 3.1; a commercial value of $4.88 per fish; and a
sport value of $92.40 per fish (Miller, 1976).
226
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Table 7-b. Increase in Urban Acres by Subdrainage Basin, 1980-2000
Major Basin
Subbasin
North Lake Washington
Swamp Creek*
North Creek*
Little Bear Creek*
North Lake Sammamish
Sammamish River
Evans Creek*
Pino Lake
East Lake Washington
Juanita Creek
Kelsey Creek
Coal Creek
South Lake Washington
May Creek
Cedar River
South Lake Sammamish
Tibbetts Creek
East Lake Sammamish
Issaquah Creek*
Green River Ba^in
Mill Creek*
Green River
Soos Creek*
Lake Young
Jenkins Creek
Covington Creek
Newaukum Creek
White River Basin*
Mercer Island
Estimated
Total
Acres
149,
15,
21,
12,
51,
11,
31,
7,
33,
16,
4,
11,
41,
10,
30,
51,
9,
4,
37,
136,
28,
18,
17,
3,
12,
35,
21,
27,
4,
645
738
062
845
188
738
533
917
728
851
973
904
120
669
451
104
165
736
203
869
460
406
414
309
160
859
261
475
109
Urban Acres
1980
(percent)
14
5
6
2
8
3
4
1
16
7
2
S
89
2
6
5
, 086
,572
, 386
, 128
,658
,534
,111
,013
, 346
.759
,922
,665
,044
,744
, 200
, 896
3 , 1 4 5
2
18
5
4
3
1
2
2
2
724
,009
,293
,234
,458
,199
463
,524
,488
927
,701
, 560
(28)
(35)
(30)
(17)
(17)
(30)
(13)
(13)
(48)
(46)
(59)
(48)
(22)
(26)
(20)
(12)
(34)
(15)
(5)
(13)
(18)
(24)
(18)
(14)
(12)
(7)
(4)
(10)
(62)
Urban Acres
2000
(perci
21
8
9
3
12
4
6
1
19
9
3
6
11
3
7
7
,590
,668
, 808
,114
,233
,744
, 160
, 329
,702
,612
, 398
,692
,165
,553
,612
,324
3,478
968
2,878
28
11
5
4
1
3
1
4
,681
,310
,888
,613
563
,867
,172
,268
,940
2,878
jnt)
(43)
(55)
(46)
(24)
(24)
(41)
(20)
(17)
(58)
(51)
(68)
(56)
(27)
(33)
(25)
(14)
(38)
(20)
(8)
(21)
(40)
(32)
(27)
(17)
(15)
(9)
(6)
(18)
(70)
Additional
Acres
Urbanized
1980-2000
7,504
3,096
3,422
986
3, 575
1,210
2,049
316
3, 356
1,853
476
1 ,027
22,021
809
1,412
L,428
330
244
869
10,388
6,076
1,430
1,414
100
343
684
341
2,239
318
Percent
Increase in
Urban Acres
1980-2000
53
56
54
46
41
34
50
31
21
24
16
L8
25
29
23
24
1 1
J4
43
'57
116
J2
44
22
23
27
J7
83
12
TOTAL
395,238
77,484 (20)
108,513 (27)
31,029
•10
*Denotes subdrainage basins with urban acre increase greater than 40 percent, considered "high
growth" for purposes of secondary impact analysis.
227
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Several additional high growth drainage basins which
could be adversely affected by nonpoint sources were identified
in King County's King County Streams: A Disappearing Resource.
Those which are over 10 percent urbanized and which were
predicted to experience at least a 50 percent increase in
urban acreage in addition to those already measured were
Lake Sammamish, Juanita Creek, Black River, Mercer/Kelsey
Creek, and lower Puget Sound.
Lakes. Population growth accommodated by expansion
of Metro's wastewater facilities may affect study area lakes
due to sedimentation and nutrient enrichment. Possible general
effects on lake flora and fishes are reviewed below.
Flora. Nutrient enrichment due to higher nutrient
loadings may increase algal and aquatic plant standing crops.
However, this may be offset in some locations by nutrient
diversion due to sewering of septic tank areas; for example,
nutrient concentrations in Lake Meridian decreased immediately
following installation of sewers in 1973 (Davis, et al.,
1978). Future nutrient loadings will depend on the degree
of urbanization and sewering decisions. Excessive algal
and plant growth would have adverse impacts on recreation
(swimming, boating, waterskiing) and aesthetics.
Fish. The impacts of additional algal or aquatic plant
growth on fish depend on the degree of such growth. Moderate
algal or plant growth could increase lake fish productivity
by providing more energy at the base of the food web. Also,
aquatic plants provide small fish protection from predators.
If aquatic plant or algal growth results in dissolved oxygen
levels below approximately 6 mg/1 in the deep portions of
lakes then the value of the lake as fish habitat would
decrease.
Mitigation Measures for Water Quality and Fisheries
Impacts
The preceding analysis has attempted to identify the
streams in which fisheries will be most affected. Inaccuracies
undoubtedly exist due to the uncertainty associated with
PSCOG's land use projections, and the imperfect nature of the
correlation between urbanization, water quality impairment,
and habitat degradation. The important point is that water
quality impairment and anadromous fish losses are occurring
due to urbanization and could continue to occur in the future.
Metro and other local agencies are conscious of this
problem and have initiated steps to mitigate it. As Figure 7-3
shows, the key to mitigating fishery losses, as well as miti-
gating flooding, streambank erosion, and sedimentation problems
228
-------
caused by urbanization, lies in controlling runoff rates
and soil erosion. Consequently, these problems have been
addressed comprehensively in drainage planning studies, in
particular the RIBCO drainage studies, Metro's 208 plan,
and local drainage planning.
RIBCO Studies. The 1974 RIBCO studies (STR, 1974a;
U. S. Army Corps of Engineers, 1974} identified present and
future water quality and drainage problem areas in the Cedar
and Green River basins, and proposed institutional and struc-
tural solutions. Alternative solution plans were prepared
for each subdrainage basin. The RIBCO studies recommended
that coordinated drainage management programs be worked out
among the various jurisdictions in each subdrainage. Recom-
mended RIBCO policies call for retention of the natural open
drainage system, wetlands protection, and floodplain zoning,
with local government being responsible for detailed faci-
lities planning.
Metro 208 Plan. The RIBCO studies were followed by
Metro's 208 areawide water quality planning. As the desig-
nated 208 agency for the Cedar-Green River basins, Metro
is responsible for areawide water quality management planning,
partially funded by EPA under the Clean Water Act. The Metro
208 plan's primary objective is the development of adequate
surface drainage control programs. The plan reiterated RIBCO's
emphasis on developing cooperative local government agreements
for drainage control in each basin.
Progress in implementing the 208 plan, as of June 1980,
has been summarized by Metro (1980i). Metro reports that
roughly two-thirds of the assigned local responsibilities
are either completed or in progress. Significant local
actions have included: 1) completion of a Union Bay demon-
stration project by Seattle, King County and Metro; 2) adop-
tion of a Surface Water Master Plan and a revised clearing
grading ordinance by Bellevue; 3) approval by Bellevue voters
of an advisory ballot issue representing a strong local
commitment for purchase of wetlands and open space; 4) develop-
ment of a draft Drainage Management Plan by Seattle ; and
5) development of options for a coordinated surface water
management program by King County staff. Metro has also made
substantial progress in developing an agressive water quality
planning and management approach.
Areas of least accomplishment by local jurisdictions
reported by Metro are 1) development and implementation of
local water quality enforcement programs; 2) development of
water quality expertise in local staff as part of the ordinance
process; 3) funding for surface water programs; and 4) imple-
mentation of best management practices for nonpoint source
pollution control.
229
-------
Of course, even full implementation of 208 plan recom-
mendations would not completely eliminate nonpoint source
impacts. Also, not all jurisdictions are moving forward to
implementation as quickly as was hoped. For example, although
creation of a surface runoff utility for King County was
identified in the 208 plan as an important method to control
runoff from urbanization, such a utility has yet to be created,
due to budgetary and other constraints.
Local Plans and Policies. The Juanita Creek Basin Plan
(King County, 1977), the Green River Basin Program, and the
City of Bellevue comprehensive drainage plan are examples
of more local drainage basin planning for solution of drain-
age problems. However, in many of the subdrainage basins
projected for large increases in urban acres, local drainage
planning has not been undertaken.
King County has proposd many policies relating to drainage
in its General Development Guide (first draft). Among these are
o Controls on development adjacent to water bodies
o Maintenance of natural watercourses
o Preservation of wetlands
Shoreline Management Act. Another possible means of
protecting water quality and fisheries from effects of
urbanization is the Shoreline Management Act of 1971.
Implementation depends greatly on local formulation and
implementation of shoreline management plans.
Summary. In summary, several institutional mechanisms
are currently in place to address fisheries and other drainage-
related impacts caused by urbanization. Although these pro-
grams are not comprehensive and their success cannot be assumed,
EPA is providing funding for 208 continuing planning.
Additional mitigation measures other than continued funding
for 208 planning do not appear appropriate at this time as
part of this EIS.
Secondary Impacts on Terrestrial Ecosystems
The principal secondary impact of growth on terrestrial
ecosystems will be conversion of coniferous and deciduous
forests, and agricultural and rangelands, to urban uses.
Secondary impacts on agricultural and forestlands, wetlands,
and floodplains are discussed later in this chapter under
secondary land use impacts.
230
-------
It can generally be stated that urban development has
adverse effects on natural terrestrial ecosystems, primarily
through destruction or extensive modification of habitat.
The Department of Game has indicated that farmlands, wetlands,
and riparian vegetation have special biological resource
values which are threatened by conversion of these areas
to urban uses.
Given the regional nature of the growth projections
examined in this EIS, it is not reasonable to further assess
the impacts of urbanization on terrestrial wildlife and ecosystems,
largely because these d-iif^r with different urban land uses. In
general, industrial and commercial land uses have substantially
less value to wildlife than low density residential uses.
The degree of impact on wildlife depends on mitigation mea-
sures implemented as part of site planning, particularly
retention of tracts or corrjdors of open space. No new miti-
gation measures for secondary impacts on terrestrial ecosystems
are proposed as part of this EIS.
Secondary Groundwater Impacts
Background
A substantial proportion of the population growth projected
for the Lake Washington/Green River Basins will rely on on-
site systems as a long-term waste disposal option. For the
year 2000, PSCOG assumes the unsewered population within
the study area to be 124,078.
Treatment Capability of Local Soils. Most of the soils
in the Renton study area have moderate to severe limitations
for use as septic tank leach fields. In particular, the Alder-
wood and Beausite soil series which cover most of the nonsewer
area have severe limitations due to shallow depth and an
extremely slow permeability in the subsoil. Everett soil
series have moderate limitations due to the extremely high
permeability of the entire soil profile. Additional data
on soil limitation ratings for septic tank leach fields are
presented in Appendix D.
Major Contaminants of Concern. The contaminants of
concern with respect to domestic on-site disposal systems
consist of those elements that can degrade the quality of
surface or groundwater resources, thereby creating direct
and indirect health hazards to human beings relying on such
sources of supply. These contaminants consist of nitrogen
compounds and pathogens. If effluent from on-site systems
enters surface water bodies, other elements such as phos-
phorus may also create water quality problems.
231
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Assessment of Impacts
Analysis of Septic Tank Failure Data. Individual septic
tanks/soil absorption systems operate at a high failure rate
in the Renton study area. The King County Health Department
estimates that between 5 and 10 percent of such systems may
be experiencing failure at any one time. Failures result
from the often unfavorable site conditions, inadequate design
of the system, poor quality construction, and lack of regular
maintenance. Two social causes may also contribute signifi-
cantly to these problems. First, the traditional view toward
on-site systems is that they are temporary solutions for
the waste disposal problem. Thus, until recently, there
was little motivation to spend more than the minimum amount
of resources in design and construction of on-site units.
Second, because septic tanks are low visibility, they are
often ignored by the homeowner, who may not even be aware
of septic tank and drain field locations.
A small survey of home loan certification forms in King
County found that 36 out of 92 systems surveyed (40 percent)
were either failing or showed signs of a potential failure
(Metro, 1980g). Common problems found included:
o Construction of driveways, garages, patios, decks,
or other structures over the drain field;
o Diversion of surface water runoff to the drain field
area;
o Compaction of the drain field by parking cars over
the field or pasturing of animals on the field;
o Irregular or nonexistent septage pumping and pro-
vision of other maintenance.
In addition, when no reserve drain field area is available,
repair of a failing system becomes extremely difficult. New
regulations of the Seattle/King County Health Department
require a reserve drain field area of either 50 or 100 per-
cent, depending upon the system's location.
When on-site systems fail and effluent surfaces, potential
risks to public health are created. In addition, the septic
tank effluent can cause nutrient enrichment problems if it
reaches streams and lakes. A less visible, but equally serious
impact, can result if septic tank effluent reaches groundwater.
Risks to groundwater from on-site systems in the study area
are reviewed below.
232
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Risks to Groundwater. "Groundwater failure" occurs
when inadequately treated effluent reaches groundwater bodies.
Groundwater failure may result from drain field installation
on excessively permeable material offering inadequate biochemical
renovation capability, or where effluent is discharged directly
into a shallow water table, receiving inadequate treatment
due to the saturated conditions. Phosphorus, bacteria, and
viruses are known to migrate over long distances under con-
ditions of saturated f]ow
Groundwater failure of an individual septic tank system
can affect the quality of water pumped from a shallow down-
gradient well, depending on the distance between the site
and the well, and on the local aquifer's hydraulic conditions.
On a broader scale, groundwater failure can seriously pollute
a regional aquifer if many systems are installed on excessively
sandy or gravelly material; this type of hazard results from
system design and site selection. Because it is extremely
difficult to locate, document or evaluate groundwater failure,
only recently have regulatory agencies recognized such failure
as a pollution hazard.
Although accurate estimates of pollutant loadings to
groundwater aquifers cannot be developed at this time due
to the lack of data on distribution pattern and density of
on-site disposal systems in nonsewered portions of the study
area, rough estimates are possible. It is generally agreed
that there are 65,000 septic tanks currently in use in the
study area. If it is assumed that average household size
is 2.7 people per dwelling and total annual wastewater flow
and nitrogen emissions in the study area can be calculated
as follows:
annual effluent discharge = 13,000 acre-feet
estimated nitrogen concentration = 40 mg/1
annual nitrogen load = 700 tons
These areawide loading data may exaggerate the importance
of groundwater quality impacts, because on-site systems may
be widely scattered and not all the effluent discharged from
these systems reaches the groundwater body. More importantly,
the loading from the on-site systems is diluted by natural
recharge and by mixing with large volumes of high quality
groundwater.
On a local basis, however, emissions from even a few
on-site disposal systems could be a major concern for pro-
tecting the quality of existing water supplies. Thousands
of shallow domestic wells are in use in the Renton study
area. Unfortunately, data are generally not available on
the chemical characteristics of water pumped from these wells.
233
-------
Data that are available generally do not indicate contamination
of groundwater from on-site systems, with the possible exception
of nitrate, which tends to be of greater concentration in
shallow, unconfined aquifers than'in deeper, more confined
aquifers; observed nitrate levels in shallow wells are, however,
well below drinking water standards.
Generally, under optimal conditions, shallow wells drilled
in Vashon till would have relatively little risk of ground-
water failure. If drain fields are installed at high densities,
or if inadequate distance is allowed between drain fields
and water supply wells, groundwater contamination would result
even in the Vashon till. For wells constructed in recessional
outwash and other highly permeable deposits, the risk of
groundwater contamination from on-site disposal systems
increases significantly, even though no evidence of surface
failure of septic tank drain fields may be detected.
Mitigation Measures for On-Site Systems
Metro-Proposed Measures. In its Wastewater Management
Plan, Metro has proposed the following recommendations for
on-site systems management in the nonsewer area:
o Establish a comprehensive program for design, con-
struction, and maintenance of on-site and community
systems.
o Identify an areawide management agency and imple-
ment a program demonstrating long-term commitment
to management of nonsewer areas.
o Establish on-site management zones in nonsewer
areas where system performance or soil condition
is poor.
o Establish a routine performance monitoring system.
o Further strengthen existing rules and regulations
to emphasize proper design and construction.
o Provide adequate staffing and funding for on-site waste-
water management programs, and provide adequate enforcement
of rules and regulations.
o Encourage experimentation with alternative technologies.
o Establish a public education program emphasizing the long-
term nature of on-site systems and proper design,
construction, and maintenance.
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Determine Groundwater Carrying Capacity. The emphasis
in the Metro recommendations is on solving the problems
created by poorly functioning or failing on-site disposal
systems, in the context of traditionally accepted defini-
tion of septic tank failure. Attention should also be
directed to the groundwater impacts of such systems, even
where apparent system failure, such as surfacing of wastewater,
may not have been observed. In the context of this objective,
it is recommended that the following additional measures
be undertaken to: 1) determine groundwater quality impacts
of on-site disposal systems, and 2) evaluate the carrying
capacity of various hydrologic or drainage units:
o Selected shallow domestic water supply wells in areas
of the Alderwood soil series on Vashon till deposit
should be monitored. These wells should be selected in
subareas with low, medium, and high densities of on-site
disposal systems. (Details of a proposed monitoring
program are given in Appendix D of the EIS.)
o A similar groundwater monitoring program should be
carried out in areas of the Alderwood soil series on
alluvial deposits and Everett soil series on recessional
outwash deposits for zones of low, medium, and high
septic tank densities.
o If the results of the shallow domestic well monitoring
programs indicate the occurrence of groundwater con-
tamination, the density of the monitoring network should
be increased and wells of medium and high depth should
also be included in the sampling program.
o Results of the monitoring program should be used to
identify areas of potential groundwater contamination
in the study area.
o Data on groundwater carrying capacity of hydrologic
units or drainage basins should be developed prior to
establishing allowable development density levels in
nonsewer areas. The carrying capacity can be deter-
mined on the basis of geologic, hydrologic, and aquifer
hydraulic conditions.
EPA Role. EPA encourages the implementation of the
previously-listed mitigation measures for on-site system
management. Without such improved management, groundwater
or surface water quality problems may result from continued
use of these systems in the nonsewer portion of the study
area.
235
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The main responsibility for implementing improvements
to on-site system management rests with local land use and
health agencies. Metro has also taken on some water quality
management responsibilities in the nonsewer areas. As part
of its decision, EPA is recommending that appropriate local
agencies take every available action to ensure that Facilities
Plan recommendations for management of on-site systems in
the nonsewer area are implemented. Of specific concern is
the need to develop a management system for subsurface system
maintenance and solids disposal.
Secondary Land Use Impacts
Study area population growth will be accompanied by
changes in land use patterns within the study area. This
section assesses three land use impacts of special import-
ance to EPA: the consistency of Metro's proposed service
area with local plans and policies, the conversion of prime
farmland to urban uses, and the impacts of development on
environmentally sensitive areas.
Consistency of the Metro Service Area with Local Land
Use Policies
EPA requires that wastewater facilities plans be con-
sistent with applicable land use plans and policies. The
major aspect of Metro's facilities planning with land use
implications, aside from the population and land use pro-
jections, is the service area map.
Metro's service area map (Figure 4-1) delineates three
categories of land within the study area: sewer service
area, nonsewer area (long-term land use certain), and the
sewer service uncertain (long-term land use uncertain). The
sewer service area consists of those lands which known local
land use policies suggest should be sewered; King County's
Sewerage General Plan, which is not a 20-year plan but is
subject to periodic amendment, provided the major basis for
mapping of service areas within King County. The nonsewer
area (long-term land use certain), consists of those lands
which local policies suggest should not be sewered over the
20-year planning period; these lands consist of small pockets
of agricultural land in unincorporated King County and Redmond.
The sewer service uncertain area consists of lands for which
there is no present land use policy guidance; these lands
are treated as nonsewer lands in the Metro Wastewater Manage-
ment Plan, and would be included within the sewer service
area once local governments designate these lands for sewer
236
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service. Therefore, the 20-year service area for the Renton
sewerage system is likely to be larger than that shown on
Figure 4-1, since it is likely that additional lands will
be designated for sewer service by local governments within
the next 20 years.
Metro's intent is to show as a designated sewer service
area only those areas which local policies dictate should
be sewered. The service area map appearing in Metro's pre-
liminary plan was assessed for potential inconsistencies
with local policies by the consulting firm Kahn/Mortimer
Associates as part of the EIS effort. As a result of that
assessment (which appears in full in Appendix A of the EIS)
revisions were made to produce the service area map appearing
in the Wastewater Management Plan. It appears that the
revised service area map appearing in the Wastewater Manage-
ment Plan is now consistent with known land use plans and
policies of local jurisdictions.
Prime Farmland Conversion
Background. An important issue in this EIS is the effect
of growth projected for the study area on prime farmlands.
This background section summarizes the following topics:
definitions of agricultural lands, rationale for protection
of agricultural lands, agricultural land resources within
King County, the economics of agriculture in King County,
and existing King County policies for agricultural land pro-
tection. Further background information on agriculture in
King County may be found in Appendix A of the EIS.
Definition of-Agricultural Lands. The terms prime farm-
land, cropland, and important farmland are important to dis-
tinguish for purposes of this analysis. The following defini-
tions will be used:
Prime farmland: Land suitable for farming or silvi-
culture with "soil quality, growing season, and moisture
supply needed to economically produce sustained high
yields of crops when treated and managed, including
water management, according to acceptable farming methods'
(Lee, 1978) . Prime farmlands are the "most efficient,
energy conserving, environmentally stable lands available
for meeting food needs" (CEQ, 1978).
Cropland: Land in cropland use. Not all cropland is
prime farmland.
Important farmland: Important farmland is that farmland
being mapped by the SCS under its current (LIM-3) mapping
237
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program. It consists of the following categories: prime
farmland, unique farmland (additional farmland used
for the production of specific high value crops), addi-
tional farmland of statewide importance (to be determined
by state agencies), and additional farmland of local
importance (where appropriate, to be determined by local
agencies).
Rationale for Protection of Agricultural Lands. Between
1967 and 1975, about one million acres of prime farmland
in the United States were converted to nonfarm use (Diderikson,
1977). This amounts to a loss of more than 3 square miles
of farmland per day. The conversion of prime farmland to
urban uses is essentially an irreversible change. National
policies to slow the conversion of prime farmland have been
developed for several reasons:
o It is increasingly important to preserve those lands
best able to produce crops because the rate of farm
productivity growth has been decreasing and export
demands are increasing.
o Farmland preservation provides open space, aesthetic,
and environmental benefits.
o In some areas, consumers benefit from lower food prices
when commodities are produced locally-
Due to these factors, EPA in 1978 established an agency-
wide policy to assure that its actions, regulations, and
programs reinforce the retention of environmentally-
significant agricultural land (EPA, 1978a).
Agricultural Land Resources Within King County. Agri-
culture played an important role in the history of King County,
in that early settlers were attracted to the county's agri-
cultural potential and accessibility to markets. Urbaniza-
tion of the county since 1950, and development of irrigated
agriculture in eastern Washington, have reduced the importance
of King County agriculture to the local, state, and national
economies. Nevertheless, preservation of remaining prime
farmland in King County is important for the economic and
environmental reasons listed previously.
The SCS has recently completed its inventory of important
agricultural lands in King County. These lands are mapped
in Figure 7-4. The prime farmlands shown on this map consist
of Class II and Class III soils. The additional farmland
of statewide importance shown on this map consists of certain
238
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ISAMMAMI3H VALLEY/
BEAR CREEK
FIGURE 7-4. MAP OF SCS IMPORTANT FARMLANDS & OF
KINO COUNTY AORICUL.T URAL DISTRICTS
-------
Class IV soils considered to be prime forestland. The SCS
map of important farmlands must be used with caution for
planning purposes, because development has occurred on some
of the lands designated as important farmlands (King County
Office of Agriculture, pers. comm.).
King County Ordinance 3064, adopted in 1977, establishes
eight agricultural districts (areas where agricultural
activities are concentrated) and designates certain lands to be
agricultural lands of county significance. Agricultural lands
of county significance are defined by Ordinance 3064 to include:
1) unincorporated lands with Class II, III and (under some
circumstances) IV soils, 2) lands not in wooded or urban uses,
3) lands where urban-level water or sewer lines are not in
place, and 4) lands with contiguous parcels greater than
20 acres.
Four King County agricultural districts are located within
the Lake Washington/Green River Basins. (See Figure 7-4.)
These are Sammamish Valley/Bear Creek, Lower Green River Valley,
Upper Green River Valley, and Enumclaw Plateau. These four
districts cover 70,635 acres (65 percent of the land in agri-
cultural districts) and contain 22,475 acres of agricultural
lands of county significance (69 percent of the lands so
designated).
Economics of Agriculture in King County. King County
gross farm receipts increased from $20.5 million in 1959
to $40.5 million in 1974. When accounting for inflation,
real increases in farm sales amounted to about 17 percent
(John M. Sanger Associates, 1978). Farm income in 1978 for
King County is estimated at $50-55 million. The 270 com-
mercial farms in King County account for 92 percent of this
farm income (John M. Sanger Associates, 1978).
Dairy products have been and continue to be the single
largest sector of King County agriculture, accounting for
46 percent of the county's gross farm receipts in 1974. Other
important sectors are ornamental horticulture (20 percent),
poultry and poultry products (16 percent), cattle and calves
(9 percent), vegetable and berries (6 percent), and other
livestock (3 percent).
In 1974, agricultural employment within King County
was estimated to be about 2,300 full-time equivalent jobs
(John M. Sanger Associates, 1978). The actual number of
farm job positions is considerably higher (about 5,600 during
peak months) due to part-time and seasonal help.
From an employment perspective, King County agriculture
is generally not considered to be economically significant
to either the regional or the local economies of King County;
agricultural employment is less than 1 percent of the total
employment of the King-Snohomish-Pierce Counties region.
However, local agriculture does result in consumer savings
for consumers who purchase products at farm stands or farmers
markets, or who pick these crops themselves.
240
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Existing Policies for Agricultural Land Preservation in
King County. King County has sought to preserve its agri-
cultural land through a series of increasingly stronger policies
and programs. These include policies in the King County
Comprehensive Plan and communities plans, agricultural policies
adopted in 1972 and 1974 (Ordinances 1096 and 1839), policies
establishing agricultural districts and agricultural lands
of county significance adopted in 1977, and policies limiting
the sewering of significant agricultural lands found in the
county's Sewerage General Plan (under revision as of early
summer 1980). The latter policies have been adopted by Metro
as well.
The main agricultural land preservation program currently
in effect in King County is the purchase of development rights
(PDR) program (Ordinance 4341). Under this program, a $50
million bond issue has been approved to acquire the voluntarily-
offered development rights for priority farmlands. The
PDR program, as well as the policies listed above, are reviewed
further in the following discussion of mitigation measures
for prime farmland conversion.
Assessment of Impacts. To assess the impacts of the
growth projected for the study area on prime farmland conver-
sion, a prime farmland conversion forecast was prepared.
Methods. Although the SCS mapped "important farmlands"
(Figure 7-4) consist of both prime farmland and prime forest-
land, the EIS forecast of agricultural land conversion con-
siders prime farmland only; it should be noted, however,
that conversion of forestland to urban uses in western Washington
is also an issue of economic and environmental concern. Also,
the EIS forecast does not consider agricultural land conversion
within the Enumclaw Plateau, since little urban growth is
projected for this region.
The forecasting method employed assumes that within
each of the remaining three agricultural districts within
the study area (Sammamish Valley, Lower Green River Valley,
Upper Green River Valley), prime farmland will be converted
to urban uses at the same rate that suitable vacant land
will be converted to urban uses; the vacant land conversion
rates were in turn calculated based on PSCOG land use pro-
jections for AAM districts. Low conversion and high con-
version scenarios were developed to establish a forecast
range. The low conversion scenario uses the PSCOG policy
land use projection, and assumes that agricultural lands
of county significance will be protected. The high con-
version scenario uses the PSCOG trends land use projection,
and also assumes that county significant lands will be con-
verted at the same rate as noncounty significant prime
farmlands.
241
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Results and Discussion. Table 7-7 presents forecasts
of conversion of prime farmland between 1980 and 2000. The
total prime farmland converted ranges between 3,950 acres
(low scenario) and 5,213 acres (high scenario) over the 20-
year period, representing a loss of 21 percent to 27 percent
of the remaining prime farmland in the three districts. In
the Sammamish Valley district, forecast conversions range
from 698 acres to 1,464 acres; in the Lower Green River Valley
district, from 3,252 acres to 3,600 acres; and in the Upper
Green River Valley district, from 0 acres to 149 acres.
These findings must be qualified by the limitations
of the forecasting methods employed. These include the
assumptions that prime farmland will be converted at the
same rate as suitable vacant land; the exclusion of hobby
farms and vacant land held for speculation from the con-
version forecast; and the lack of an up-to-date statistical
inventory of prime farmlands.
Several factors will influence whether the low con-
version scenario or the high conversion scenario is more
likely to occur. These include the county's PDR program,
the King County Sewerage General Plan process, urbanization
trends, and existing zoning constraints.
Of these factors, the success of the PDR program is
perhaps the most critical. As shown in Table 7-7, lands
eligible for Priority 1 of the PDR program include all the
prime farmland in the Upper Green River Valley, about 36
percent of the prime farmland in the Sammamish Valley, and
only 10 percent of the prime farmland in the Lower Green
River Valley. Therefore, if the development rights of 100
percent of the Priority 1 lands were to be purchased by King
County in all three districts, prime farmland in the Upper
Green River Valley district would be completely protected,
whereas most prime farmlands in the Sammamish Valley and
the Lower Green River Valley districts would not be protected.
Prime farmland conversion will have environmental and
economic impacts which will depend largely on the size and
productivity of the prime farmland parcels converted. Under
either scenario, much of the acreage converted is prime farm-
land that is not of county significance and not included
in Priority 1 of the PDR program. Although some of the non-
county significant and non-Priority 1 prime farmland is pro-
ductive land within municipal boundaries, much of it is of
limited productivity because it is in small parcel sizes,
or not being actively farmed. Conversion of these noncounty
significant and non-Priority 1 prime farmlands, nevertheless,
represents the irreversible loss of a nonrenewable resource.
242
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Table 7-7. Forecast of Prime Farmland Conversion*
Agricultural Districts
NO
Item
Total acres
Prime acres
Agricultural land of
county significance
(acres)
Land eligible for
priority 1 of PDR
program (acres)
Vacant land conversion
rate, 1980-2000 (policy)
Vacant land conversion
rate, 1980-2000 (trend)
Prime farmland con-
version, 1980-2000
(low forecast)
- acres
- % of total prime
farmland
Prime farmland con-
version, 1980-2000
(high forecast)
- acres
- % of total prime
farmland
Sammamish
Valley
11,
6,
1,
2,
1,
535
100
735
193
16%
24%
698
11
464
24
Lower Green
River Valley
18,840
12,000
1,510
1,518
31%
30%
3,252
27
3,600
30
Upper Green
River Valley
2,965
865
865
2,180
6%
17%
0
0
149
17
Study Area
Total
33,340
18, 965
4,110
5,891
3,950
21
5,213
27
*Excludes Enumclaw Plateau,
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Mitigation Measures for Prime Farmland Conversion.
Overview of Types of Mitigation Measures. Measures
to mitigate the loss of agricultural lands to urban uses
have been comprehensively reviewed in a recent EPA (1979b)
EIS for wastewater facilities improvements in Modesto,
California, located in the highly-productive San Joaquin
Valley- Table 6-8 lists and evaluates the mitigation
measures developed for that EIS.
Mitigation Measures for Metro Wastewater Management Plan.
Of the general types of mitigation measures shown in Table 7-8
several are already in place in King County. For purposes
of this EIS, the most important of these include the PDR
program, King County's Sewerage General Plan, and Metro Resolu-
tion 3380 adopting the Sewerage General Plan. The effectiveness
of these measures in mitigating the conversion of prime farmland
is assessed below, and additional mitigation measures are
then identified.
PDR Program. The PDR program has established three
priority levels for acquisition of development rights. The
first priority consists of 6,000 acres of lands most threatened
by urban development in the Sammamish River Valley, the Lower
Green River Valley near Kent, and the Upper Green River Valley,
and 1,700 acres of farmland producing food for human consumption.
The second priority consists of farmlands in the lower Snoqualmie
Valley and Enumclaw Plateau, mostly dairy farms. The third
priority consists of all other farmlands located within the
county's agricultural districts.
Although it is not possible to predict exactly how much
acreage that will be protected by the PDR program, the PDR
program cannot offer complete protection for prime farmlands
threatened by development because: 1) some landowners will
refuse to participate in the program, and 2) the initially
authorized $50 million is inadequate to purchase development
rights for the third priority lands which constitute most
of the prime farmland within the study area. As of late 1980,
the initial $50 million in bonds had not been sold due to
litigation. Though the possibility exists that more funds
will be authorized, the PDR program can be considered only a
partial mitigation measure for the loss of prime farmland within
the study area, since it is unlikely that development rights
for the third priority lands will be purchased.
King County Sewerage General Plan. As initially adopted,
the King County Sewerage General Plan excluded designated
agricultural lands of county significance as defined in
Ordinance 3064 from local service areas, thereby prohibiting
the sewering of these lands. A proposed amendment to the
county's Sewerage General Plan (which has been adopted by
Metro - see below), establishes the Priority 1 lands in the
244
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Table 7-8.
PRIME AGRICULTURAL LAND MITIGATION MATRIX
MLUUM P»0*0.i ID
IHrUMDrTATIGM
LOCAL
ITkTl
no-
IPUJ,
rrrr or
NCAtUU
«..U-
LA-
I*C*»-
TIVI
ominrrATim
u-u.
fcCPJ-
CUL-
Tmua
H/PMDAOI
O1MCT
IM-
DIPUtCT
WHO*
• Wiirr
•UM
LOMC
KM
UUL> errtmvfHui
ITKMC
• Liorr
m-
•MOMH
tow*id oon-pr >•• l*nd*
y/ urfttjn t n/'f\j. [ rid -t ur.
(or lom]'<.rB qr
«ty o7T,ii
n«* pron
L-iir-l I •- F ____ I'aant
r d 1 «t r Lbut 1 n.g
r^.r.ni. r.i.t-ir.» ~.i,,.7. ,r f.n. .,,1^1^,. i i^r
/•.r/,,r-,,-uw .u^^l. fur l,,,»l ,m.w.»
•
•
•
•
fonm.ion cMfricl.nt.
•
•
•
•
•
•
• 1 1 « 1
• 1 1 » 1
•
•
•
•
•
•
SOURCE: EPA, 1979b.
245
-------
PDR program as the "designated" lands to which sewer service
will not be provided. Once this amendment is adopted, its
main effect will be to make it more difficult to convert
Priority 1 lands to urban uses, regardless of whether the
development rights to these lands have been purchased. As
previously discussed, the Priority 1 lands include all the
prime farmland in the Upper Green River Valley district,
36 percent of the prime farmland in the Sammamish Valley
district, and only 16 percent of the prime farmland in the
Lower Green River Valley district. Because the Sewerage
General Plan affords no protection to non-Priority 1 prime
farmlands, it can be considered only a partial mitigation
measure for prime farmland conversion.
Metro Resolution 3380. Metro's adoption of King County's
Sewerage General Plan (Resolution 3380) prohibits Metro's
sewering of unincorporated "designated agricultural lands",
defined as Priority 1 lands under the PDR program. Because
Resolution 3380 affords no protection to non-Priority 1 farm-
lands (like the Sewerage General Plan), or to Priority 1
lands within the city limits of Kent and Redmond, it can
be considered only a partial mitigation measure for prime
farmland conversion.
Additional Mitigation Measures. Within the existing
institutional framework in the study area, several additional
mitigation measures exist which could more completely mitigate
the loss of prime farmland.
o Metro could establish a procedure to ensure that local
land use agencies evaluate, with public input, the
impacts to agricultural lands resulting from exten-
sion or connection to the Renton system of any new
interceptor. Such an evaluation could consider alter-
natives and mitigation measures to avoid adverse impacts.
o King County could modify its Sewerage General Plan. The
proposed amendment to the Sewerage General Plan could be
strengthened by broadening the"definition of designated
farmland to include some or all prime farmland within
King County agricultural districts that is not designated
Priority 1 in the PDR program.
o The Cities of Kent and Redmond could adopt policies
similar to King County to protect Priority 1 farmland
located within municipal boundaries. Metro could then
modify Resolution 3380 to reflect these policies.
246
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Impacts on Sensitive Areas
Background. An important issue in this EIS is the effect
of study area projected growth on environmentally sensitive
areas. Environmentally sensitive areas, as defined by King
County, consist of soil-related sensitive areas, floodplains,
and wetlands. EPA policy requires that an assessment of
floodplains and wetlands impacts be made and that adverse
impacts be avoided or minimized if no practical alternative
to the action exists. At the local level, King County has
recognized the importance of environmentally sensitive areas
by mapping those areas considered sensitive to development and
by strengthening its policies for protection of these lands.
Assessment of Impacts. In this analysis, the locations
of high growth subdrainage basins and sensitive areas are
mapped. Impacts of projected urbanization on soil-related
sensitive areas, wetlands, ^nd floodplains are then discussed.
Identification of High Growth Subdrainage Basins. Eight
high growth subdrainage basins within the study area were
identified earlier in the secondary impacts analysis (see
Table 7-6) ; these subdrainage basins are projected to show
increases in urban acres greater than 40 percent (the study
area average) between 1980 and 2000. Figure 7-5 shows the
location of the high growth subdrainage basins.
The generalized locations of environmentally sensitive
areas are shown in Figure 7-6. The original mapping of sen-
sitive areas was done by King County (King County Department
of Planning and Community Development, Planning Division,
1980); the composite map of sensitive areas was prepared
by Metro (1979a). Comparison of Figures 7-5 and 7-6 can
indicate which subdrainage basins have the greatest potential
for secondary adverse impacts on sensitive areas. These
subdrainage basins are identified in the following sections.
Soil-Related Sensitive Areas.
Characteristics and Potential Impacts of Urbanization.
Areas identified on Figure 7-6 as soil-related sensitive
areas include: Class III slide and slippage (landslides)
areas, Class III seismic areas, erosion areas and coal mine
areas.
Landslide hazards are commonly associated with the hill-
sides of many of the major valleys. These areas are char-
acterized by steeply sloping unconsolidated glacial deposits
that are very susceptible to gravity sliding.
247
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011)4
/ WASflNOTO
FIGURE 7-5, LOCATION OF HIGH GROWTH SUBDRAINAGE BASINS
-------
-LEGEND-
I MIL MLATEO SENSITIVE AREAS
I lEIKJSIO*, SLIM-SLIFPAM, SEISMIC
t COAL mm AREAS)
SOURCE KIN4 COUNTY DEPARTMENT Of PLANMINS C COMMUNITY
DEVELOPMENT, DIVItiOH Of ^ L AHDI H« . * SCMSlTIVC AJMAI
HAP FOLIO* I»T|, Pu»fT BOUND COUNCIL OF »OVC»«HfMTI
•LAND USE tUITAtlLlTV ADALYtit*. 1»TI '
(*LIDC-«LIF«AM), FLOOOtMt, VCTLANO* 1 COAL
riNt AUCAS MtULATID lY SCCTIOH I OF
OlOiMAHCC 31(1.
tNOHOHIIH COUNTY- SOIL RELATED SENSITIVE
CHI Tim A SANE AS KINS COUNTY.
FIGURE 7-C. COMPOSITE MAP OF" SENSITIVE
AREAS WITHIN STUDY AREA
-------
The entire Lake Washington/Green River Basins region
is seisraically active (King County, 1980) . In most river
basins, the extensive deposits of alluvial material and
unconsolidated glacial materials contribute to an especially
high susceptibility to earthquake damage.
Erosion hazard areas are a concern mainly due to sedi-
mentation, a process which occurs as eroded matter accumulates
in receiving waters (streams, channels, lakes). Eventually,
sedimentation can result in costly expenditures to dredge
or otherwise remove the unwanted material. In addition,
the threat to the proper functioning of delicate ecological
systems is an important concern since both erosion and sedi-
mentation are frequently accelerated by land use modification.
The abandoned subsurface mine workings associated with
coal activates present potential danger of surface collapse
and leakage of noxious gases. Many abandoned mines have
been filled or partially filled by natural caving processes,
which poses a potential danger of subsidence. Although coal
mine areas are generally quite remote, occasional problems
do arise (King County Department of Planning and Community
Development, 1978).
Subdrainage Basins with Greatest Potential for Adverse
Impacts on Soil-Related Sensitive Areas. Based on the com-
parative locations of high growth subdrainage basins and
soil-related sensitive areas (Figures 7-5 and 7-6), the fol-
lowing subdrainage basins appear to have the greatest poten-
tial for adverse impacts: Issaquah Creek, Mill Creek, Soos
Creek, and the White River basin. In addition, the following
subdrainage basins, although not defined as high growth,
also have a high potential for a significant adverse impact:
Sammamish River, Coal Creek, May Creek, Tibbetts Creek, Green
River, and Newaukum Creek.
It should be recognized that this identification serves
only to "red flag" subdrainage basins with the greatest po-
tential for adverse impacts. To evaluate the direct impact
of development on soil-related sensitive areas, site-specific
analyses must be conducted.
Mitigation Measures. In recent years, King County has
adopted a series of policies and ordinances which provide
guidelines for development of soil-related sensitive areas.
In addition, many cities in King County have developed policy
guidelines to direct development away from soil-related sensitive
areas. To the extent that these policies and ordinances
are implemented, adverse impacts of urban development on
soil-related sensitive areas will be reduced. The following
section reviews and evaluates existing King County policies.
250
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Historically, policy concerning soil-related sensitive
areas in King County has been included within open space
policy. The open space element of the county comprehensive
plan, together with subsequent amendments (Ordinance 1096
and Ordinance 1683) , provides the existing basis for policy
protection of soil-related sensitive areas. In recent years,
the need for new and more specific policies has been recognized.
King County's proposed General Development Guide (first draft)
contains policies which, if adopted, would replace the existing
policies relating to soil-related sensitive areas. These
policies discourage development on slopes greater than 40
percent, and in landslide and coal mine hazard areas, and
recommend reduced development intensity as slopes increase.
Implementation of policies relating to soil-related
sensitive areas has been provided for with the adoption of
King County Ordinance 4365 in July 1979. This ordinance
defines and incorporates maps of soil-related sensitive areas,
and establishes a review process on a case-by-case basis
for development proposals in these areas. Before the ordinance
car. become effective, however, administrative guidelines
to implement its provisions must be developed. These include
uniform standards for development approvals, provisions to
expedite the case-by-case review process, and incentives
for dedications of lands for open space.
ye t lands .
Characteristics and Potential Impacts of Urbanization.
In general, wetlands are lands where saturation with water
is the dominant factor determining the nature of soil develop-
ment and the types of plant and animal communities inhabiting
the area. The wetlands shown on Figure 7-6 include marshes,
bogs and swamps. Classification of wetlands by subtype is
often difficult due to gradational physical, chemical, and
biological characteristics. In the larger marshes, shallow
water is usually retained throughout the drier season. In
contrast to bogs, marsh substrate is generally mud or muck
with minor areas of peat. Swamps are similar to marshes
except they are characterized by trees and larger shrub
vegetation .
Wetlands are significant with respect to the wildlife
they support and their role in maintaining water quality.
Wetlands support a variety of wildlife, including small mammals,
waterfowl, and other birds. Wetlands can also act as natural
water purifiers, filtering out sediments and stripping nut-
rients, and thus helping mitigate the effects of upstream
urbanization on downstream areas.
The main impact of urbanization on wetlands is the outright
loss of the wetlands through conversion to urban uses. This
may happen by filling, diking, draining, or otherwise removing
the water from the land. When this happens, the wildlife,
water quality, and aesthetic benefits of the wetlands are
lost.
251
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Subdrainage Basins with the Greatest Potential for Adverse
Impacts on Wetlands. Based on the existence of a relatively
large amount of wetlands, the following subdrainage basins
appear to have the greatest potential for adverse impacts on
wetlands: Evans Creek (a high-growth subdrainage basin), Coal
Creek, and Covington Creek. These are general red flag areas,
based on a very general level of analysis. Impacts of indivi-
dual projects on wetlands should be evaluated on a case-by-case
basis.
Mitigation Measures. The King County Sewerage General
Plan prohibits sewering of designated King County wetlands.
Metro adopted the provisions of the plan for existing
unincorporated areas in its Resolution 3380. Policies on
sewering of development on wetlands in incorporated areas of
King County, and in Snohomish and Pierce Counties, are more frag-
mented and varied. Study area cities could adopt stronger
policies to prohibit or discourage sewering of wetlands within
existing municipal boundaries.
King County's proposed General Development Guide "(first
draft) contains proposed policies for additional protection
of wetlands in the county. These policies encourage retention
of wetlands in their natural state and discourage development
adjacent to wetlands where wetlands would be adversely
affected.
Floodp lains.
Characteristics and Potential Impacts of Urbanization.
The floodplain designations on Figure 7-6 are 100-year flood-
plains. These areas are lands expected to be covered by
floodwaters at least once over a 100-year period. Partial
flooding may occur more frequently. Excessive storm runoff
and snowmelt are generally the sources of floodwaters.
Floodplains are significant areas with respect to their
value as occasional watercourses and their value as wildlife
and fishery habitat features. Natural floodplains in an
overbank flow situation carry floodwaters at greatly reduced
velocities, as compared to a diked or modified river channel
designed to carry floodwaters within the confines of the
channel. Thus, natural floodplains minimize erosion and
detain the flow somewhat to lessen flooding in downstream
areas. Floodplains also contain riparian habitat areas
which support a great variety of animal life and provide shade
and sustenance to stream fish.
The impacts of urbanization on floodplains occur through
urban development on the floodplain area, and also through
urban development of the floodplain1s watershed. Develop-
ment of the floodplain area can eliminate riparian vegetation
and its benefits to wildlife and the stream community.
252
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Streams arc often channelized and diked to protect invest-
ments on floodplains, thus further destroying riparian vege-
tation. Sometimes streams overcome these structural control
measures, causing economic loss and physical danger to people
occupying the floodplain.
Development of a floodplain 's watershed increases the
areal extent of a flood of a given frequency (e.g., 10-year
flood, 100-year flood) . This Js caused by higher runoff
water due to impervious surfaces, and less infiltration of
water into the ground. Thus, the 100-year floodplain area
actually grows larger as urbanization of a watershed plug reuses ,
Subdrainage Bauinu with the Greatest Potential for
Floodplain Impacts. Based on the existence of relatively
extensive floodplains, the following subdrainage basins appear
to have the greatest potential for adverse floodplain impacts:
Evans Creek, Coal Creek, Cedar River, Issaquah Creek, Mill
Creek and White River basin. Four of these subdrainages arc
high growth, whereas two (Coal Creek and Cedar River) are not.
These are general red flag areas identified by a very general
level of analysis. Impacts of individual developments on flood-
plains should be analyzed on a case-by-case basis.
Mitigation Mea^urex. The King County Sewerage General
Plan prohibits sewering of designated floodplain areas in King
County. Metro adopted the provisions of the plan for existing
unincorporated areas in its Resolution 3380.
Implementation of floodplain protection programs in
incorporated areas of King County, and in Snohomish and Pierce
Counties, is more fragmented and varies with local government
policies. Some floodplain areas (adjacent to water bodies
larger than 20 acres in size or streams with mean annual flow
greater than 20 cubic feet per second) may be partially
protected from development by local shoreline management
plans prepared pursuant to the State Shoreline Management Act
of 1971. Study area cities could adopt stronger policies
prohibiting or discouraging the sewering of floodplains within
existing municipal boundaries.
King County's proposed General Development Guide (first
draft) contains proposed policies for additional protection of
floodplains in the county. These policies discourage develop-
ment within the 100-year floodplain and prohibit development
within the floodway.
The federal Flood Insurance Program requires participating
communities to participate in mandatory floodplain management
and flood protection measures, and to apply common sense
and good engineering practice in reviewing and approving
building permit applications.
253
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Summary of Mitigation Measures for Sensitive Areas.
A number of laws, plans, and policies currently exist for
the protection of sensitive areas within the study area.
In addition to those already mentioned, an important mitiga-
tion measure is the SEPA's requirement for preparation of
EISs when individual development projects could have a signi-
ficant effect on the environment. To the extent that the
existing laws, plans, and policies are implemented, impacts
on sensitive areas will be mitigated.
Metro could also establish a procedure to ensure that
sensitive area impacts are evaluated by local land use
agencies prior to any interceptor extension or connection
to the Renton system. Such analysis could incorporate public
input, and consider alternatives and mitigation measures
for adverse impacts.
Public Service Systems
Most local governments within the Lake Washington/Green
River Basins have policies encouraging the coordination of
growth and the provision of public services. This section
of the EIS discusses the effects of growth projected for
the study area on public service provision.
Appendix A to this EIS describes in detail the existing
management system and plans and policies regarding service
provision, wastewater management, water supply, drainage,
solid waste management, recreation, social services, trans-
portation, and electricity and gas. This section of the
EIS, for each of the services, summarizes the existing
management system, identifies known existing capacity problems
and describes the potential impacts of projected growth.
Since comprehensive data on local system capacities are
generally not available for all public service systems,
emphasis is placed here on regional, macrolevel public service
impacts. Mitigation measures for adverse impacts of growth
on public services, consisting of local comprehensive and
special-purpose plans and policies, are discussed at the
end of this section.
Wastewater Management
Existing Management System. Within the study area,
sewerage service is provided by local cities, water districts,
and sewer districts, and by Metro, acting as a sewerage
"wholesaler". Metro component agencies and existing Metro
wastewater facilities within the study area are described
in Chapter 1 of this EIS.
254
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Existing Capacity Problems. As part of the identi-
fication of near-term actions for its facilities plan, Metro
facilities with capacity problems were identified. In addition
to these capacity problems, scattered local collection systems
managed by cities and water or sewer districts are also experi-
encing capacity problems, or will experience such problems
in the near future. In general, little information is available
on local collection system capacity within the study area.
Impacts of Growth. PSCOG projects the sewered population
within the study area will double over the next 20 years, from
340,890 in 1980 to 6H1.170 in the year 2000. In addition
to the facilities planned in Metro's Draft Wastewater Manage-
ment Plan, additional non-Metro facilities (in particular,
collection sewers) will also be required to serve this growth.
Some appreciation for the additional local collector sewers
needed to serve projected growth may be gained by examining
PSCOG's projections of-sewered urban land within the study
area. PSCOG's policy projection, shown in Table 7-9, predicts
that sewered urban land will increase by 39,349 acres between
1980 and 2000. This amounts to 61.5 square miles of land,
one-tenth of the entire study area, that must be provided
with local collector sewers by Metro's component agencies
over the next 20 years.
Numerous local sewer system projects will therefore
be required to serve projected growth. Many of the needed
local sewer projects have been identified in the comprehen-
sive sewer plans which must be prepared by every local sewer
agency within King County. If sewer system projects are
not implemented in a timely fashion, growth could continue
to create local sewerage system capacity problems.
The unsewered population growth within the study area
will also place service demands on local agencies, particularly
if increased on-site system management activities are imple-
mented. Overall, PSCOG projects the study area's unsewered
population to decrease from 196,198 in 1980 to 124,078 in
the year 2000. However, this net decrease is attributable
to much of the currently unsewered population becoming sewered
over the next 20 years, and does not show that new population
in outlying areas will continue to rely on on-site systems.
Water Supply
Existing Management System. Almost all of the study
area is supplied with water by the City of Seattle Water
Department, either directly or indirectly through approxi-
mately 36 retail water purveyors (cities and water districts).
Seattle-supplied surface water from the Cedar River and Tolt
River is the main source of" water for most of the study area
residents, with some outlying communities supplied by local
we 11s .
255
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Table 7-9. PSCOG Projections of Sewered Urban Acres
by Subdrainage Basin, 1980-2000
Major Basin/Subbasin
North Lake Washington
Swamp Creek
North Creek
Little Bear Creek
North Lake Sammamish
Sammamish River
Evans Creek
Pine Lake
East Lake Washington
Juanita Creek
Kelsey Creek
Coal Creek
South Lake Washington
May Creek
Cedar River
South Lake Sammamish
Tibbetts Creek
East Lake Sammamish
Lssaquah Creek
Green River Basin
Mill Creek
Green River
Soos Creek
Lake Young
Jenkins Creek
Covington Creek
Newaukun Creek
White River Basin
Mercer Island
Study Area Total
1980
7,264
2,799
3,668
797
3,953
2,710
931
312
13,565
6,173
2,656
4,736
4,368
947
3,421
3,499
2,665
138
696
10,142
4,903
2,905
1,551
44
415
288
36
643
2,534
45,968
1990
13,206
5,809
6,177
1,220
6,266
3,818
1,497
951
17,608
8,455
3,031
6,122
6,877
1,540
5,337
4,029
2,955
201
873
15,159
7,241
4,122
2,558
77
661
419
81
1,480
2,761
67,386
2000
19,416
8,347
9,348
1,721
8,171
4,561
2,420
1,190
19,407
9,513
3,382
6,512
7,652
2,047
5,605
4,305
2,990
260
1,055
20,800
9,889
5,306
3,822
111
872
669
131
2,965
2,601*
85,317
Lncrease
1980-2000
12,152
5,548
5,680
924
4,218
1,851
1,489
878
5,842
3,340
726
1,776
3,284
1,100
2,184
806
325
122
359
10,658
4,986
2,401
2,271
67
451
381
95
2,322
67
39,349
Percent
Increase
1980-2000
167.3
198.2
154.9
115.9
106.7
68.3
160.0
281.4
43.1
54.1
27.3
37.5
75.2
116.2
63.8
23.0
12.2
88.4
51.6
105.1
101.7
82.7
146.4
152.2
110.1
132.3
263.9
361.1
2.6
85.6
*Decrease represents probable error in PSCOG projection.
SOURCE: PSCOG .
256
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Existing Capacity Problems. Water supply capacity problems
are of two types: regional and local. Regional water supply
issues have been most recently addressed by the Comprehensive
Regional Water Plan (Complan) prepared by the water department
of Seattle (1980). The Complan projects that Seattle service
area water demand will increase from a current demand of
155 MGD to 253 MGD in the year 2025. Since the existing
system's capacity is 210 MGD (excluding groundwater), the
Complan concludes that an additional supply of 50 MGD is
needed by the year 1995. The Complan tentatively recommends
that the North Fork Tolt River, with a firm yield of 70 MGD,
be developed to provide the additional supply; development
of the North Fork Snoqualmie River could become the preferred
water source if its costs were equivalent to the North Fork
Tolt River and if it were feasible.
Locally, scattered water supply problems related to
insufficient capacity have been noted in areas such as the
City of Kent and King County Water Districts 94, 105, and
111 (King County Department of Building and Land Development,
pers. comm.); these capacity deficiencies have not been com-
prehensively documented. Lack of adequate water systems
has been an important concern in developing the Tahoma/Raven
Heights Community Plan (Monohan, 1980). Also, in some rural
areas, water systems are not sufficient to meet county fire
flow requirements.
Impacts of Growth. Growth projected for the study area
will generate additional needs for regional water supplies
and local water system improvements. Study area growth is
primarily"responsible for the need for Seattle to develop
an additional surface water supply, since 90 percent of the
population growth projected by Seattle's Complan is projected
to occur in "suburban purveyor areas", incorporating most
of the study area. The Complan project's total costs, through
the year 2025, will be $221 million.
At the local level, numerous local water system improve-
ment projects will be required to serve projected growth.
Many of the needed local water improvement projects have
been identified in the comprehensive water plans prepared
by water purveyors within King County- If planned water
system improvement projects are not implemented in a timely
fashion, growth could create local water system capacity
problems.
257
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Drainage and Flood Control
Existing Management System. Local drainage facilities
planning and implementation are the responsibility of cities
and counties within the study area. The Army Corps of Engineers
is responsible for several major flood control drainage projects,
The Corps has also widened and deepened the Sammamish River
Channel to prevent flooding, and periodically dredges the
Duwamish River and Lake Washington Ship Canal to maintain
navigation.
Existing Capacity Problems. The urbanization process,
through development in flood-prone areas and through paving
of previously permeable surfaces, increasing runoff volumes
and flow rates, creates the need for drainage and flood control
measures. At the local level, drainage improvement projects
to manage increased storm flows can be found in the capital
improvements program of virtually every local government within
the study area. Many local drainage problems were identified
as part of the RIBCO urban drainage study in 1975.
At the regional level, the major existing drainage problem
within the study area is flooding along tributaries to the
Green River caused by insufficient capacity of the river
to handle peak storm flows. To minimize flood damage and
also ensure continued multiple use of the Green River, the
Green River Basin Program was initiated by several local
agencies in 1978.
Impacts of Growth. Projected population growth will
generate the demand for additional drainage and flood control
facilities, as well as for nonstructural control measures.
These drainage facilities include both the types of trunk
drainage facilities described in the RIBCO urban drainage
study (e.g., holding ponds, drainage channels, streambank
protection with riprap, erosion control weirs, pumping stations,
levee improvements) and local collector facilities. If
drainage programs are not implemented in a timely fashion,
growth could continue to create both local and regional drainage
and flooding problems.
The financing of drainage system maintenance in King
County is an important service issue for the future. Currently,
the county requires developers to maintain residential storm-
water control facilities for only 1 year following construction,
after which the county "may" take over responsibility. A
countywide surface water utility district has been discussed
as a method for financing drainage system maintenance, the
costs of which have been estimated at $42.5 million over
the next 30 years (Penhole, 1980b).
258
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Solid Waste Management
Existing Management System. The local solid waste manage-
ment system involves the basic steps of collection, transfer,
and disposal. The King Subregional Council is the Solid Waste
Management Board for King County- Most of the solid waste in
the study area is collected by private companies. King County
and the City of Seattle operate the main transfer stations and
landfills which serve the study area. The Cedar Hills landfill
is the major landfill serving the study area, and will play an
even greater role in solid waste disposal as rural landfills
within King County are phased out. The Cedar Hills landfill
has enough capacity to last for approximately another 20 years
(King County Department of Building and L'and Development, pers.
comm.). The feasibility of establishing waste-to-energy
conversion plants as an alternative to continued landfilling
is currently being studied by King County.
Existing Capacity Problems. No near-term capacity prob-
lems appear to exist with the solid waste management system.
Impacts of Growth. Growth projected for the study area
will generate additional needs for solid waste transfer and
disposal facilities. A rough estimate of the additional
solid waste generated by population growth can be made using
the RIBCO solid waste plan per capita figures of 19.77 pounds
per capita per day for solid waste generation and 5.74 pounds
per capita per day for solid waste remaining for ultimate
disposal; these figures include residential, commercial/industrial,
and special wastes. Using these figures and the PSCOG policy
projection for the year 2000, solid waste generation within
the study area can be projected to increase from 1.94 to
2.91 million tons per year between 1980 and 2000, and solid
waste remaining for disposal can be projected to increase
from 0.56 to 0.84 million tons per year.
Recreation
Existing Management System. A number of federal, state,
and local agencies provide recreation services to study area
residents. Within the study area and its vicinity, residents
enjoy a wide range of recreation opportunities. In particular,
rivers, lakes, marine shorelands, and the inland waters of
Puget Sound offer many opportunities for water-oriented recreation.
Existing Capacity Problems. King County's draft General
Development Guide distinguishes among four types of parks:
neighborhood (5-10 ac) , community (20-40 ac) , resources-
based (1-100 ac) and major urban (at least 100 ac). No com-
prehensive data on park capacity problems exist. Through
the communities planning process, deficiencies in one or more of
these types of parks have been noted within different communities
259
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planning areas. In addition, a Bureau of Outdoor Recreation
(1977) study of the recreational needs of the study area
and its vicinity identified boating facilities, swimming
beaches, and shoreline access as high priority recreational
needs common to all local jurisdictions.
Impacts of Growth. Growth projected for the study area
will generate additional demands for parks and recreation
facilities. The King County draft General Development Guide
recommends 5 acres per thousand persons as the standard for
major urban parks (the draft General Development Guide
also contains standards for neighborhood and community parks,
but within built-up areas only). Using this standard, the
projected increase in population for the study area of 321,000
between the years 1980 and 2000 would require 1,600 acres
of additional major urban parks.
Social Services
Existing Management System. Schools and police and
fire protection typically fall within the category of social
services. Schools within the study area are run by 15 inde-
pendent school districts. Centralized administrative support
is provided by Educational Service District (BSD) 121 in
King County and ESD 189 in Snohomish County. Police and
fire services within the study area are provided by cities
within their boundaries and by counties in unincorporated
areas.
Existing Capacity Problems. No comprehensive data exist
regarding existing capacity problems of schools, police,
or fire services. Through the communities planning process,
deficiencies in one or more of these services have been noted
within individual communities planning areas. As a general
rule, schools are seldom provided for in advance of development,
and school capacity is often the major social service concern
in rapidly growing areas.
Impacts of Growth. Projected population growth will
generate demand for additional social services. If these
services are not provided in a timely fashion, the quality
of social services within the study area could deteriorate.
It is possible to estimate the number of additional
students who will require classrooms by using ESP 121's
planning rule of thumb estimate of 20 students per 100 persons
added within King County. Using this figure, the projected
increase in population for the study ^area of 321,000 between
the years 1980 and 2000 would generate an additional 64,200
students. Of course, schoolroom capacity would not be needed
for all 64,200 at one time, since students generated early
in the planning period would be leaving the public school
system prior to the year 2000.
260
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Transportation
Existing Management System. Management of roads and
highways within the study area is the responsibility of the
federal and state Departments of Transportation, PSCOG, and
cities and counties. (This section is limited to examining
the impacts of projected growth on roads and highways, and
does not consider airports, railroads, or ferry services.)
Metro is responsible for operating the regional mass trans-
portation system.
Existing Capacity Problems. Capacity problems exist
for both local roads and regional highways. Some of these
have been identified in communities plans. PSCOG is in the
process of identifying regional and subregional highway prob-
lems as part of its current updating program for the 1990
Transportation System Plan.
Impacts of Growth. Projected population growth will
generate additional person-trips and vehicle-miles travelled.
Many highway and transit improvements have been programmed
by PSCOG, local governments and Metro to meet projected demands,
Metro's 10-year capital expenditure needs for transit improve-
ments alone were recently estimated at $1.9 million (Penhole,
1980a). If transportation facilities and services are not
provided in a timely fashion to meet increased demands, or
if strategies to reduce vehicle-miles-travelled are unsuc-
cessful, additional congestion and increased travel times
could result. This could have localized air quality impacts.
A good indicator of the increase in transportation demand
is the number of home-to-work trips. Table 6-10 shows PSCOG1s
projection of home-to-work/college trips by place of residence
and place of work for 10 planning districts in Pierce, King,
and Snohomish Counties. The trip projections are based on
PSCOG1s policy population projection, identical to that used
for Metro's wastewater facilities planning. The data in
Table 7-10 indicate that the five transportation planning
districts located within the study area are all expected
to show significant increases in trips from home and trips
to work.
Electricity and Gas
Existing Management System. Electricity is supplied
to most of the study area by Puget Sound Power and Light
(PSP&L); in Snohomish County, electricity is supplied by
Snohomish Public Utility District. In 1979, 78 percent of
the electricity supply by PSP&L came from hydroelectric plants
with thermal sources accounting for the remaining 22 percent.
Natural gas- is supplied in the study area by Washington
Natural Gas. Supplies are purchased from the Northwest Pipe-
line Corporation.
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Table 7-10. Projected Hare-Work/College Trips by Place
of Residence and Place of Work
Trips from Home
in this District
Trips to Work
in this District
ro
CTi
NJ
District
1. Tacoma/LakewDod
2. Puyallup, Spanway, S. E. Pierce County
3. Federal Way, Auburn, Kent, Maple Valley*
4. Renton, Tukwila, Barien, Sea-Tac*
5. Seattle, South of Ship Canal
6. East Lake Washington*
7. North Seattle's Shoreline
9.
10.
Montlake Terrace, North Creek, Alderwood
Manor*
Edmunds, Lynnwood*
Everett and Suburban Areas
County Totals
Pierce
King
Snohomish
1977
157.2
88.2
119.8
137.0
201.5
184.3
203.6
37.0
69.6
63.0
245.4
846.2
169.6
2000
216.9
192.7
234.6
168.1
227.4
286.9
212.7
103.7
114.0
129.0
409.6
1,129.7
346.7
Percent
Change
+ 38.0
+118.5
+ 95.8
+ 22.7
+ 12.9
+ 55.7
+ 4.5
+180.3
+ 63.8
+104.8
+ 66.9
+ 33.5
+104.4
1977
179.1
41.1
83.5
113.3
412.6
104.4
199.7
9.2
39.9
82.3
220.2
913.5
131.4
2000
255.4
103.9
175.7
182.7
505.9
186.1
239.5
33.1
88.4
144.2
359.3
1,289.9
265.7
Percent
Change
+ 42.6
+152.8
+110.4
+ 61.3
+ 22.6
+ 78.3
+ 19.9
+259.8
+121.6
+ 75.2
+ 63.2
+ 41.2
+102.2
*Denotes districts within Lake Washington/Green River Basins.
SOURCE: PSCOG, 1979a.
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Existing Capacity Problems . The near-term outlook for
electricity supplies in the study area is uncertain. That
electricity supplies could be a problem is best demonstrated
by a pending petition filed in late 1979 by PSP&L with the
Washington Utility and Transportation Commission. This peti-
tion requests a 4-year restriction on new electricity hook-
ups where other fuel types would be more efficient or where
supplies are more available; the main effect of this petition
would be to limit new hook-ups for residential space heating
or water heating. In contrast to the electricity outlook,
the near-term outlook for natural gas within the study area
is considered good.
Impacts of Growth. Population growth projected for
the study area will generate additional energy demands. Current
uncertainties in factors such as the future of nuclear power,
energy pricing policy, and the role of conservation, among
others, make projections of 20-year energy demand and supply
quite difficult, and such projections are not attempted here.
Mitigation Measures for Public Services Impacts
In an effort to assure the coordination of growth and
provision of public services, local agencies within the study
area have developed numerous comprehensive and special purpose
(functional) plans and policies. The status of plans and
policies is described in detail in Appendix A of this EIS.
Some of the more important plans and policies affecting public
services provisions are listed below.
Comprehensive Plans. King County General Development
Guide [first draft), community plans in King and Snohomish
Counties, comprehensive plans prepared by cities.
Wastewater Management Plans. Sewer district compre-
hensive plans, King County Sewerage General Plan, Metro
Resolution 2933, nonsewer policies of Seattle-King Counties
and Snohomish County Health Departments.
Water Supply. Water district comprehensive plans,
Seattle Complan.
Drainage and Flood Control. Metro 208 plan, local govern-
ment drainage policies. Green River Basin Program.
Solid Waste Management. King County Solid Waste Manage-
ment Plan.
Transportation. PSCOG 1990 Transportation System Plan
update, PSCOG subregional transportation plans.
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To the extent that these and other local plans and policies
regarding public services provision are implemented, the
potential adverse impacts of growth on public services will
be mitigated; if public services plans and policies are not suc-
cessfully implemented, localized service deficiencies could
create changes in growth patterns, but these are unlikely
to be of sufficient magnitude to affect the study area's
projected growth rate or the phasing of Metro's wastewater
facilities. At this time, development of additional mitigation
measures as part of this EIS does not appear warranted.
Secondary Impacts on Public Finance
Background
Growth accommodated by the Metro Wastewater Management
Plan will affect the balance between public costs and revenues.
Public costs are incurred with the provision of services
such as police, fire protection, streets and roads, water,
sewers, libraries and public health. Revenues are obtained
from property taxes, sales taxes, utility taxes, charges
for services, fines and transfers from other (such as state
and federal) governments.
The municipal budgeting process and collection of reve-
nue to pay for public services are governed by a well-defined
set of regulations. According to Washington state law, local
government budgets must be balanced; that is, revenues must
equal costs.
The amount of revenue collected is not specifically
limited, but there are some constraints. Revenue from pro-
perty taxes in any year may not exceed 106 percent of the
largest property tax collection in the previous 3 years,
with three exceptions: (1) voters may suspend this limitation
one time only, for a period of 1 year; (2) voters may authorize
the sale of general obligation bonds to be repaid by an extra
property tax levy; and (3) new development may be added to
the collection base subject to certain rules. Sales tax
receipts are derived from a distribution of state sales tax
revenues. Municipal bonds, issued by local governments to
cover capital costs, are limited by the total assessed valua-
tion in the jurisdiction (for general obligation and local
improvement district bonds) or the revenue of the enterprise
(for revenue bonds) .
Responsibility for Provision of Services
Public services in the study area are provided by a
combination of local government entities. Within cities,
King County is responsible for county streets and roads;
health; law, safety, and justice (excluding police); solid
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waste collection; and some parks. The city provides general
government, police and fire protection, parks and recreation,
water and sewer services. Some cities also provide libraries.
In unincorporated areas of the county, King County provides
general government; streets and roads; law, safety and justice
(including sheriff); solid waste collection; and parks and
recreation. Fire protection, water and sewers are provided
by special districts.
Further details regarding the existing management system
for study area public services may be found in the previous
section assessing secondary public services impacts.
Fiscal Outlook of the Study Area
Interviews were held with finance officers and city
treasurers in the seven largest cities in the King County
portion of the study area and with staff of the King County
budget division to assess the fiscal outlook. Officials
in six of the seven cities - Auburn, Bellevue, Kirkland,
Kent, Redmond, and Renton - indicated that the fiscal condi-
tions and outlooks of those cities are similar. In all six,
diversified tax bases provide substantial property and sales
tax revenues. Continuing development, especially of com-
mercial and industrial uses, allows property tax collections
to increase at a greater rate than 6 percent per year and
helps in covering the cost of services to residential areas.
Sales tax receipts, which rise not only with new commercial
development but also with inflation and real income gains
(the amount by which increases in income exceed inflation),
contribute additional funds.
Several of the cities place major importance on user
fees to generate revenue not only for water and sewer ser-
vice but also for development processing and recreation pro-
grams. A notable example is the City of Kent, which serves
a large population in the unincorporated area around the
city, and charges for services in an effort to assign the
costs of those services to the people who actually use them.
Several of the cities have additional sources of revenue -
such as business and occupation tax and gross receipts tax -
available to them when the constraints imposed by the 106
percent limit become too severe. All of the cities have
major portions of their bonding capacity uncommitted, and
none has had trouble passing bond issues when they have
been submitted to the voters. In general, these cities have
adopted a conservative approach to budgeting, overestimating
expenses and underestimating revenues, in an attempt to main-
tain solvency and respond adequately to the service needs
and demands of their residents.
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There are, nonetheless, some differences among these
six cities. Some have substantial cash reserves available
to cover emergency funding requirements, while others have
virtually none. Some of the cities anticipate significant
population growth in the future, in some cases involving
annexations as well as new development within current city
boundaries, while others expect only minor infill development.
Officials in the six cities expressed confidence in
their fiscal soundness and their abilities to handle future
growth. They based this optimism on increasing sales tax
revenues, future possibilities of additional revenues from
other sources (user charges, business and occupations tax),
the future possibility of suspending the 106 percent property
tax limit and careful management practices.
The seventh city, Mercer Island, differs from the other
six in several ways. It is completely contained by the is-
land, almost fully developed and almost completely residen-
tial. The residential character of development means that
the city must rely heavily on property taxes for locally-
generated revenues, knowing that most costs will rise at a
greater rate than 6 percent per year and thus that the city's
finances face continual strain in the future. Voters suspended
the 106 percent limit this year, leaving that option unavailable
in the future. Even the very limited potential for future
population growth and the knowledge that whatever growth
does occur will probably not significantly increase city
costs (because it will occur within the existing framework
for service provision) does not bolster the city's fiscal
outlook. Smaller cities in the study area with development
characteristics similar to Mercer Island are likely to find
themselves in the same fiscal condition.
The King County government, which provides some services
countywide and some to the unincorporated area, shares the
fiscal outlook of the City of Mercer Island, although for
different reasons. The services provided by the county -
primarily law, safety and justice, streets and roads, and
public health - are difficult or impossible to finance with
user charges (parks and recreation in the unincorporated
area may be an exception). Therefore, the county must rely
on property and sales taxes for revenue. Its property tax
levies and sales tax receipts differ, however, between the
incorporated and unincorporated areas; property tax levies
in the incorporated areas (city territory) are lower because
the county provides fewer services there, and sales tax receipts
are lower because the cities share in the revenue. The county
policy which encourages new development in existing urban
concentrations makes it likely that the county will receive
a smaller share of the fiscal benefits from that development
than it would if construction in unincorporated areas were
more acceptable.
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The county also has more difficulty than the cities
in mounting and passing bond issues, because a county issue
must be approved by residents of both the incorporated and
unincorporated areas. The greater diversity of population
and interests in the countywide electorate dilutes the appeal
of any county proposal and requires a major political effort
to adopt a bonding program.
It should be noted that neither county special districts
nor Snohomish nor Pierce Counties budget officials were
interviewed for this study, and consequently the foregoing
description of county finances presents only a partial pic-
ture .
Mitigation Measures for Fiscal Impacts
Local jurisdictions within the study area are implementing
a variety of measures to finance the public costs of growth.
For example, as part of its General Development Guide program,
King County is examining the fiscal impacts of four alterna-
tive development patterns, and fiscal considerations will
play an important role in determining which alternative is
selected. At this time, development of additional mitigation
measures as part of this EIS does not appear warranted.
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Chapter 8
EPA ALTERNATIVES AND PROPOSED ACTION
EPA Alternatives
Overview
EPA' s objective for the 201 construction grant program
is to assist public agencies in meeting their responsibility
for working toward the goals of the Clean Water Act. The
primary methods EPA and the State of Washington use to meet
water quality goals are to establish water quality standards
necessary to protect the beneficial uses of streams, and
to administer the National Pollution Discharge Elimination
System (NPDES), whereby effluent discharge permits contain
terms intended to maintain water quality standards. EPA
will consider a wastewater treatment construction grant appli-
cation to assist Metro in meeting the terms of its NPDES
permit, and to protect water quality -
EPA's implementation procedures for the National Environ-
mental Policy Act (NEPA) require, in addition to considering
the grant applicant's alternatives, that EISs explicitly
consider alternatives available to EPA. These alternatives
may include structural or locational alternatives not investi-
gated by the grant applicant, or can be administrative only.
The administrative options may include such choices as funding
or not funding the proposed action; funding portions of
the project; funding the project in stages; or providing
a reduced or increased level of funding. Administrative
options can also relate to grant conditions, including
impact mitigation measures that EPA may wish to make part
of any subsequent grant offer to the applicant.
New Structural Alternatives
EPA, as its discretion, may propose, within its EIS,
facility alternatives in addition to those proposed by a
grant applicant. In the case of Metro's Wastewater Manage-
ment Plan for the Lake Washington/Green River Basins, EPA
believes that Metro has examined a full range of long-term
facility alternatives. These include both centralized and
decentralized approaches, as well as several discharge options
Based on public and agency comments on the draft plan, Metro
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developed new alternatives which are presented in the final
plan and analyzed in this Final EIS. These include deferral
of decisions on wastewater treatment configuration for flows
from the north part of the study area presently tributary
to West Point. Also included was a new outfall location
alternative for discharge to deep water of Puget Sound off
Duwamish Head. Additional new facilities approaches do
not appear warranted at this time as part of this EIS.
Alternative mitigation measures could be considered prior
to EPA's final decision.
Administrative Alternatives: Approval and Funding
Approve and Fund One Alternative. EPA funding is based
on a determination that the applicant's preferred alternative
is approvable. An approvable alternative must be cost-
effective and environmentally acceptable. If these require-
ments are met, federal funds could be provided. Funding
levels and timing would be dependent on availability of
funds and funding priorities. Under the Clean Water Act,
EPA may provide grants of up to 75 percent of eligible project
costs. It is possible that the EPA would be able to provide
75 percent funding for only a portion of the approved program.
Recent EPA construction grant annual funding for Washington
State has ranged from close to $80 million in 1978 to near
$60 million in 1980. Annual funds in the near future may be
expected to be less than this $60-80 million range. Administra-
tion or Congressional actions or national economic trends may
affect this estimate. Full EPA funding of this project could
therefore be expected to require the commitment of all
Washington's share of federal construction grant funds for
several years. This in turn would require denying funding
for other projects within Washington.
Actual distribution of federal funds to projects in
Washington is determined by the State Department of Ecology.
The most recent state priority list shows that design funds
for this Metro project will not be available for several years.
The State estimates that the maximum annual amount of federal
funds made available for this project is likely to be approxi-
mately $20 million per year.
Washington voters recently passed a bond measure providing
$315 million over 10 years for wastewater treatment projects.
This program will be administered by the Department of Ecology.
It is anticipated that this money will be used to fund pro-
jects at between 50-75 percent of eligible costs. Due to
the wastewater treatment needs of small communities, Metro
has in the past received only about 12 percent of the funds
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from past state bonding authorities. The State of Washington
expects that Metro's fair share of the new bonding authority
will be higher, based on the realization that a majority
of the state's population and a significant portion of the
state's remaining wastewater treatment needs are in the
Seattle metropolitan area. Therefore, state funds may be
available to supplement federal funds for this Metro project.
EPA approval of the recommended program would be approval
of the entire program. Since the entire program is necessary
to prevent water quality problems, EPA funding would be
dependent on Metro's commitment to implement the entire
program. If only a portion of the program were to be com-
pleted, EPA would not have achieved its intent in approving
the recommended program, and water quality standards vio-
lations could occur.
Planning of project phasing should recognize that some
portions of the recommended program are essential to achieve
water quality objectives. For example, under the recommended
program, project phasing should guarantee that the tunnel
and outfall will come on-line in time to transfer to Puget
Sound any major increased discharge from the treatment plant.
If major increased discharge preceded completion of the
tunnel and outfall, unacceptable water quality impacts in
the Duwamish River might occur.
Approve and Fund No Alternatives. If the applicant's
preferred alternative is not found to be cost-effective
and environmentally acceptable, EPA approval requirements
would not be met and federal funds could not be provided.
Also, if no funds were appropriated by Congress for the
201 program, no funds could be provided, even for an
approvable plan. In either of these cases, the applicant's
preferred alternative would need to be funded entirely from
state and local sources; otherwise, it might not be built.
In the former case, increases in costs to local ratepayers
might be expected. In the latter case, impacts such as
those discussed in this EIS under the no-project alternative
could be expected, including serious water quality and
fisheries impacts.
Approve and Fund More than One Alternative. If more
than one alternative were found to be cost-effective and
environmentally acceptable, EPA could approve and fund
whatever cost-effective and environmentally acceptable
alternative was preferred by the grant applicant. The dis-
cussion above, concerning funding availability and timing,
would still be applicable in this case.
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Funding of Project Phases. If Metro proposed to confirm
the West Point "de-emphasis" policy at this time and transfer
to Renton flows from the north study area now going to West
Point, Metro would stage design and construction in two phases.
Phase 1, consisting of expansion of treatment plant and
solids handling facilities of 72 MGD, the effluent tunnel/
outfall, and Phase 1 of the Redmond connection, would start
in 1981 and be complete by 1985. Phase 2, consisting of
expansion of treatment and solids handling capacity to 99
MGD, Phase 2 of the Redmond connection, and the North Creek/
Hollywood connection, would start in 1986 and be complete
in either 1991 or 1993, depending on the facility.
In this case EPA would provide initial federal funding
for only Phase 1 of the preferred program. An alternative
would be to provide funds at this time for both phases; this
alternative does not appear necessary given funding constraints,
the relative independence of the two phases (i.e., Phase 2
is not a necessary part of Phase 1), and their separation
in time.
Funding Beyond the 20-Year Capacity. EPA cost-effectiveness
guidelines require that cost-effectiveness analyses be based
on a planning period of 20 years. As a general rule, EPA
does not fund facilities beyond their 20-year capacities.
If Metro's recommended program is selected, it is unlikely
that EPA would fund the tunnel and outfall to Puget Sound
beyond their 20-year capacities. The costs of additional
incremental capacity would therefore need to be funded en-
tirely from local sources.
Administrative Alternatives: Grant Conditions
A number of potential adverse environmental impacts
have been identified throughout this EIS. In many cases
measures can be taken to mitigate these impacts. Mitigation
measures have been discussed at various places in the body
of this EIS and are summarized in the EIS SUMMARY (Table S-l) .
Specific mitigation measures are the responsibility of various
federal, state or local agencies. For example, several
agencies have responsibilities to implement 208 plan recom-
mendations necessary to mitigate nonpoint source impacts
of urbanization on surface water in the study area. Certain
mitigation measures can also be taken by Metro.
Where EPA determines that mitigation measures are necessary
to prevent or minimize unacceptable adverse impacts of the
selected project, and that such measures could be taken by
Metro, EPA may place conditions on the award of subsequent
grants to require that Metro take appropriate mitigative
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actions. Grant conditions can include specific monitoring
requirements, requests for supporting ordinances, and a
variety of other controls on the construction and operation
of the wastewater treatment and disposal facilities.
EPA regulations require EPA to ensure that a grantee
has the authority to fulfill grant conditions. Suggested
mitigation measures not included as grant conditions, which
are beyond Metro's authority, were included in the EIS to
give the public an idea of measures that could be implemented,
and which agencies have responsibility for them. Although
these additional measures are not part of the proposed action,
and the proposed action is not dependent on them, EPA believes
it is appropriate to present them in the EIS.
Proposed Action
Evaluation of Alternatives
Facilities plan alternatives were evaluated by EPA
according to a set of specific decision criteria. These
criteria reflect those factors considered by EPA to be most
important to the decision, based on analysis of technical
information in the EIS and public and agency comments.
Generally, criteria were included based on EPA judgement
concerning the importance and distinctness of the issue,
the measurability of alternatives' effects in terms of the
issue, and the difference among alternatives' effects in
terms of the issue. Decision criteria were explicitly
prioritized and weighted for use in evaluating alternatives.
Weights were assigned based on EPA judgement concerning degree
of public concern, EPA legal requirements, and the magnitude
and duration of effects.
f
The selected decision criteria and weights are as follows
Criteria Weight
1. Public health, considering public exposure
to contaminants such as pathogens and heavy
metals. 130
2. Economic effect on salmon, bottom fish and
shellfish populations. 120
3. Possibility of cumulative water quality
deterioration in Puget Sound. 120
4. User rate increases. 120
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Criteria Weight
5. Present net worth. 105
6. Potential for water quality standards
violations. 90
7. Flexibility to respond to future new
information, conditions, or decisions. 80
8. Risk and consequences of plant upset. 65
9. Construction impacts to neighborhoods
and parks. 65
10. Landslide and seismic risk. 65
11. Cost-sharing potential with CSO projects. 40
Total 1,000
EPA rated eight alternatives according to these decision
criteria. The alternatives rated were as follows:
No Project
A-l - Secondary treatment with nitrification at Renton;
discharge to Duwamish River.
A-3 - Standard secondary treatment at Renton; discharge
via tunnel and outfall off Seahurst Park.
A-5 - Standard secondary treatment at Renton; discharge
via tunnel and outfall off Alki Point.
B-l - Secondary treatment with nitrification at Renton
with discharge to Duwamish River; new secondary
plant at Kenmore with discharge via tunnel and
outfall off Richmond Beach.
A-l1 - Same as A-l but with deferred decision on north
study area.
A-31 - Same as A-3 but with deferred decision on north
study area.
A-5' - Same as A-5 but with deferred decision on north
study area.
The purpose of the evaluation system is to clarify for
decision makers and the public the key factors that led to
the preferred action.
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Selection of the Preferred Action
EPA proposes to approve for federal funding a long-
term wastewater management program for the Renton study area,
including expansion of the Renton treatment plant's secondary
treatment capacity to 72 MGD by the year 1990, construction
of solids handling facilities at the Renton treatment plant
site, and construction of a tunnel and outfall for discharge
of treated effluent to Puget Sound.
Metro's draft plan considered two alternative locations
for the Puget Sound outfall: Alki Point and Seahurst Park.
EPA finds that, based on environmental criteria alone, ex-
cluding costs, Alki Point is an environmentally preferable
discharge location. This is due to the greater circulation
of Puget Sound waters off Alki, compared to Seahurst, which
allows much more rapid dispersion of effluent off Alki. This
is important in relation to concern about long-term water
quality trends in Puget Sound, especially in shallower em-
bayments.
A plan including a Seahurst outfall has a present net
worth cost which is $66 million less than the cost of a plan
with an Alki outfall. This EIS has concluded, based on all
available information, that no major adverse impacts to Puget
Sound can be predicted with a Seahurst outfall. Therefore,
EPA considers a plan with a Seahurst outfall to be the cost-
effective alternative, and to be environmentally acceptable.
From a technical standpoint, EPA has been unable to
conclude that the environmental advantages of the Alki site
represent overriding concerns. Such a conclusion would be
necessary for EPA to approve an alternative other than the
cost-effective alternative. However, this is largely because
little can be conclusively stated about long-term cumulative
impacts to Puget Sound, especially to the area south of Alki
Point, from major municipal discharges. Therefore, the con-
clusion as to possible overriding benefits of an Alki discharge
is, to a great extent, a judgement about the desired degree
of risk avoidance in the face of poorly known future conditions,
An Alki discharge would provide a greater degree of certainty
that long-term problems would be avoided.
EPA believes that the judgement as to the desired level
of risk-avoidance is a decision in which local citizens,
acting through their elected officials on the Metro Council,
should have a major voice. EPA will therefore make a final
decision on potential overriding benefits of an Alki discharge,
based on the decision of the Metro Council. If the Metro
Council selects a plan with a Seahurst discharge location,
and that plan is certified as acceptable by the Washington
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Department of Ecology, EPA would approve that plan for federal
funding. If the Metro Council concludes that the relative
advantages of the Alki discharge location are overriding
considerations, and selects a plan with an Alki discharge
location, and DOE certifies that plan, EPA would consider
that as persuasive evidence that Alki has overriding benefits
and would approve that plan for federal funding. Due to
severe constraints on the availability of federal grant funds
for wastewater treatment facilities, EPA does not predict
that additional federal funds will be available for an Alki
plan beyond what would be available for a Seahurst plan.
Therefore, the cost increase of the Alki plan would have to
be assumed by state and/or local sources.
Regardless of the selected outfall location, EPA believes
that there is a need for additional studies as part of the
design of the selected route, and for monitoring of outfall
performance and Puget Sound water quality conditions. Various
grant conditions and recommendations are presented below
which address these concerns.
Rationale for Key Trade-Offs
Rationale for Centralized Treatment Plant. A centralized
plant configuration was found to be less expensive in most
cases than a dual configuration including both Renton and
Kenmore plants. A centralized system also avoids the con-
struction impacts of a new plant and an additional tunnel
and outfall. Further, it reduces the potential for effluent
contact with more than one recreational beach area. Although
addition of a Kenmore plant and outfall increases overall
system reliability and may decrease potential long-term
effects on Puget Sound or Elliott Bay, these considerations
were not felt to counter-balance the advantages of a cen-
tralized system. No major difference between the two con-
figuration strategies were found in the areas of water quality
standards, fisheries, or seismic hazards.
Rationale for Deferring North Service Area Decisions.
The proposed action would defer the decision on the issue
of where to treat future wastewater flows from the North
Lake Washington/Lake Sammamish area. That area is presently
connected to Metro's West Point plant. Although a decision
now would provide greater public certainty about future con-
ditions, a deferred decision offers the possibility of sub-
stantial cost savings and a more logical overall wastewater
system. Adding the north service area to the Renton system
would provide a greater proportion of secondary treatment
for regional wastewater. However, leaving that area in the
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West Point system, in addition to avoiding the costs and
impacts of connection facilities and greater operation and
maintenance costs, provides more flexibility to respond to
changes in service area growth, and discharges more effluent
in northward-flowing waters of Puget Sound.
Rationale for Diverting Discharge from Duwamish River
to Puget Sound. The overriding factor favoring diversion
from the Duwamish River is the ability to avoid water quality
standards violations and possible losses to the valuable
salmon fishery and to bottom fish. These problems would exist
even if nitrification is added to the treatment process.
There will not be water quality standards or fisheries problems
with a Puget Sound discharge. On the other hand, diversion
entails construction impacts from the tunnel and outfall,
the possibility of diluted effluent contacting popular re-
creational beaches, and the need to construct nonmodular
facilities sized for 50-year loads. No major differences
were found in the area of cost, assuming a Seahurst discharge,
or in the area of long-term Puget Sound impacts. Overall,
the judgement of EPA decision makers is that the water quality
and fishery concerns, especially considering the greater
possibility of plant upset with more sophisticated treatment,
outweigh the relatively short-term construction impacts,
and the possibility of effluent contacting beaches. No adverse
impact to the beneficial uses of beaches is expected from
occasional contact with diluted effluent.
Rationale for Alternative Puget Sound Discharge Locations.
A Seahurst discharge would experience occasional periods
of several days or more of very poor dispersion in which
diluted effluent would remain in the central East Passage
area, before moving south. Some effluent would probably
move into Commencement Bay and south Puget Sound before
exiting north through Colvos Passage. With an Alki discharge,
there would probably be good dispersion to the north within
a few days under all tidal conditions, with little movement
of effluent south of Alki Point. An Alki discharge would
therefore offer greater protection against any possibility
that diluted effluent might contribute over time to cumulative
impacts to Puget Sound south of Alki. It is not presently
predicted that cumulative impacts could be expected with a
Seahurst discharge, but little conclusive information exists
as a basis for prediction.
A plan with a Seahurst outfall would be $66 million
less expensive, in present net worth terms, than a plan with
an Alki outfall. The Seahurst route also would have slightly
less construction impact than the Alki route. Although the
Alki route has a shorter tunnel length, it would require
over 10 miles of open cut construction and would involve
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more neighborhood disruption. An Alki route has the advantage
of providing opportunities for cost sharing with combined
sewer overflow control" projects, if such projects were under-
taken .
The Alki and Seahurst outfall locations appear to be
largely equivalent in terms of public health concerns, fisheries,
water quality standards, reliability, and seismic or landslide
hazards. Overall, the choice seems to be whether the greater
long-term risk-avoidance of an Alki discharge is worth its
greater cost.
Proposed Grant Conditions
The following grant conditions are intended by EPA to
mitigate certain potential adverse impacts identified in
this EIS. Several are intended to provide for additional
study after selection of the preferred plan. These include
conditions concerning additional cultural resources, geo-
technical, and oceanograhic studies; a construction site
plan and site restoration plan; a spoils disposal plan; and
a monitoring plan. Other conditions pertain to project con-
struction timing, to ensure that discharge facilities are
completed prior to the onset of major new outputs from treat-
ment facilities. Another condition is intended to meet EPA
policies on agricultural lands, floodplains, and wetlands,
while affirming the authority of local land use agencies
over land use planning decisions.
Several additional recommendations are also made which
encourage implementation of various ongoing studies:
Proposed grant conditions are as follows:
1. Prior to construction Metro shall ensure that an
historical/archeological survey is conducted for
the selected tunnel/outfall route and at any other
construction sites other than the Renton treatment
plant. The results of the survey shall be sent
to the State Historic Preservation Officer (SHPO).
Any subsequent recommendations by the SHPO shall
be formally considered in accordance with require-
ments of Section 106 of the National Historic
Preservation Act. Any SHPO recommendations shall
be forwarded to EPA. If cultural resources are
discovered during construction at the Renton treat-
ment plant, construction shall stop until a pro-
fessional archeologist has assessed the significance
of the resources.
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2. Prior to construction, Metro shall prepare and
submit to EPA and the Washington State Department
of Ecology its proposed water quality monitoring
plan for the Renton Puget Sound discharge. The
monitoring plan shall include at least the proposed
parameters to be measured, sampling locations and
sampling frequency. EPA and DOE shall have the
opportunity to review and comment on the proposed
monitoring plan.
3. During predesign work, Metro shall conduct detailed
geotechnical and oceanographic studies of the selected
tunnel/outfall location. The scope of work for
these -studies shall be made, available to the public
and shall be submitted to ETPA and DOE. These studies
shall include, at a minimum, an identification and
assessment of soil instability and seismic hazards
along the route, based on site-specific investigations,
and development of siting or construction methods
to reduce risks to acceptable levels. The results
of the detailed studies shall be reported in a document
which will also be available to the public and sub-
mitted to EPA and DOE for review. Metro shall hold
a public meeting to discuss the results of these
studies, and a responsiveness summary for the meetings
shall be prepared.
4. Before any EPA construction funds are awarded, Metro
shall have an approved sludge disposal plan.
5. Metro shall establish a formal procedure to ensure
that, prior to any new interceptor extension or
connection to the Renton system, local land use
agencies shall evaluate, with public input, the
potential impacts of sewered development on environ-
mentally sensitive areas. Those include prime agri-
cultural lands, wetlands and floodplains. The pro-
cedures shall stipulate that consideration be given
to alternatives that would avoid adverse impacts
and recommendations to mitigate adverse impacts.
6. Should connections which transfer wasteloads from
the West Point system to the Renton system be found
cost-effective in final West Point facilities plan-
ning, Metro shall ensure that construction of the
selected tunnel and outfall from the Renton treatment
plant will be completed prior to completing con-
struction of any such West Point system connection.
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7. Before construction, Metro shall prepare a plan,
in coordination with EPA and DOE, which sets out
the measures that will be taken to minimize adverse
impacts to Seahurst Park from construction of the
tunnel and outfall, if Seahurst is the selected
outfall location. The plan shall also include
measures that will be taken to complete restoration
of the park, after construction is completed. These
measures shall be incorporated into construction
contracts. The restoration plan shall include an
estimate of the time required to complete restoration,
8. Metro shall prepare a spoils disposal plan. The
plan shall include specific methods and locations
for handling and disposal of spoils from tunnel
construction, and shall present measures to minimize
adverse impacts from spoils storage and disposal.
EPA additional recommendations are as follows :
1. EPA recommends that appropriate local agencies take
every available action to ensure that the facilities
plan recommendations for management of on-site waste-
water systems in the nonsewer area are implemented.
Of specific concern is the need to develop a manage-
ment system for subsurface system maintenance and
solids disposal in King County.
2. EPA encourages Metro to continue to investigate
and implement measures to minimize near-term water
quality problems in the Duwamish River during design
and construction of diversion facilities.
3. EPA recognizes the importance of the "Duwamish
Pollutant Inventory" study and recommends that Metro
work actively with appropriate agencies to ensure
implementation of the recommendations of that study.
4. EPA recommends that PSCOG and Metro work closely
together to develop realistic 50-year wasteload
forecasts for the purpose of sizing nonmodular
facilities.
5. The Washington State Department of Ecology has
begun a Puget Sound sensitive area study to identify
and prioritize sensitive areas, develop a monitoring
strategy, and develop DOE program direction, in
coordination with other agencies. EPA believes
this is an important first step toward gaining
an understanding of water quality trends in Puget
Sound. EPA encourages DOE to build on this plan
280
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by implementing the chosen monitoring strategy,
so as to acquire information about long-term Puget
Sound water quality conditions, in relation to
wastewater discharges.
281
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Chapter 9
COORDINATION
Introduction
Section 6.203 of EPA's procedures for implementation
of the National Environmental Policy Act requires that EISs
discuss the extent and results of coordination activities
conducted prior to publication of EISs. This chapter describes
the involvement of government agencies, interest groups,
and the public in general in determining the scope and content
of this EIS. Public participation activities for the Waste-
water Management Plan and EIS are further documented in Metro's
Public Hearings and Meetings Summary dated April 1981, and
in Metro's public participation Compendium, a limited com-
panion document to the Wastewater Management Plan.
Public Participation
Public participation for this EIS has been coordinated,
and, where possible, integrated with the full-scale public
participation program undertaken by Metro in preparing its
Wastewater Management Plan. Key EIS public participation
activities to date are summarized below.
Information Brochure
In August 1979 EPA published a brochure entitled Deci-
sions on Water Quality in the Renton Area. This widely-
distributed brochure provided background information on the
Wastewater Management Plan being prepared by Metro, listed
and discussed key issues for the EIS, described EPA's role
in decision making and in preparing the EIS, and identified
future public involvement opportunities. The brochure also
included a Notice of Intent inviting members of the public
to attend the initial project "kickoff" and scoping meetings
Scoping Meeting
An initial kickoff/scoping meeting was scheduled for
September 16, 1979. Because attendance was much larger
than anticipated and exceeded the capacity of the meeting
room, the kickoff/scoping meeting was rescheduled and held
on October 17, 1979.
283
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Because the kickoff/scoping meeting was jointly held
by Metro and EPA, both wastewater planning and EIS issues
were discussed. In addition to Metro's presentation,
presentations were made by EPA staff and the EIS consultant
regarding EPA1s role in preparing the EIS and some of the
important issues that would be addressed in the EIS.
Following the presentations, most public comments
addressed the Wastewater Management Plan. However, one issue
was raised by a citizen regarding the importance of air quality
considerations in the EIS. This citizen felt that the EIS
should consider the inadequacy of the existing monitoring
station network for carbon monoxide within the study area;
without more monitoring stations in certain "hot spots",
the commenter felt, it would be difficult to predict and
mitigate the air quality impacts of future growth in the
study area. The EIS consultant responded at that time that
the EIS would probably not undertake new efforts to predict
and mitigate future air quality problems unless the population
projections used for wastewater planning were inconsistent
with those used for the Washington State Implementation Plan;
these population projections have been determined to be con-
sistent in this EIS (see Chapter 6).
Notice of Intent
On October 2, 1979, EPA's formal Notice of Intent to
prepare an EIS was published in the Federal Register.
Presentation to Wastewater Plan Citizens Advisory
Committee
On January 23, 1980, the EIS consultant presented a
status report on the EIS to the Renton 201 Citizens Advisory
Committee. The different emphases of the Wastewater Manage-
ment Plan and EIS were discussed.
Public Meeting on Alternatives
On February 6, 1980, Metro held a public meeting to
obtain public input on the advantages and disadvantages of
various wastewater management alternatives. EPA staff and
the EIS consultant attended this meeting, gave a short pre-
sentation on the status of the EIS, and participated in the
small group discussions which were the focus of the meeting.
284
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Public Meetings on Preliminary Plan
In mid-May 1980, Metro held a series of public meetings
on its preliminary plan; in these meetings the contents of
the plan were discussed by Metro staff and consultants,
followed by a question-and-answer session. EPA staff or
the EIS consultant were in attendance at each of these
meetings. Two questions arose specifically related to the
EIS: 1) whether the EIS would focus on a preferred action
or alternative actions, and 2) whether the EIS would address
the land use impacts of a Kenmore treatment plant.
Public Meetings and Hearings on Draft Plan and EIS
Five public meetings and two public hearings were held
by Metro and EPA in January 1981 to receive comments on Metro's
Draft Wastewater Management Plan and EPA's Draft EIS. Legal
notices of the meetings and workshops were mailed on December
4, 1980- On that day, about 2,000 copies of the draft plan
and EIS summaries were mailed to persons who had previously
indicated interest.
The Metro/EPA public informational meetings were:
January 6, 7:00 p.m., Alki Congregational Church, West
Seattle — chaired by R. R. "Bob" Greive, King County
Council member from District 8 and Metro council member.
About 150 persons attended.
January 7, 7:30 p.m., Puget Sound Power and Light
Auditorium, Bellevue -- chaired by Bruce Laing, King
County Council member from District 6 and Metro Council
Water Quality Committee member. About 30 persons
attended.
January 13, 1981, 7:30 p.m., Burien Public Library,
Burien -- chaired by Beth Bland, Mayor of Mercer Island
and chairman of the Metro Council Water Quality Committee.
Over 175 persons attended.
January 14, 1981, noon, Fourth Floor Conference Room,
Exchange Building, Seattle -- chaired by Michael Hildt,
Seattle City Council member and Metro Council Water
Quality Committee member. About 35 persons attended.
January 15, 1981, 7:30 p.m., Kent City Council Chamber -
Kent -- chaired by Gary Grant, King County Council member
from District 9 and Metro Council Water Quality Committee
member. About 20 persons attended.
285
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The Metro/EPA public hearings were:
January 21, 1981, noon, Fourth Floor Conference Room,
Exchange Building, Seattle.
January 2, 1981, 7:00 p.m., Puget Sound Power and Light
Auditorium, Bellevue.
Both public hearings were chaired by Beth Bland, Metro
Council Water Quality Committee chairman. About 120
persons attended the Seattle hearing, and about 40
persons attended the Bellevue hearing.
Persons attending the public meetings and hearings had
numerous oral and written comments on the draft plan and
EIS. EPA has transcripts of the public hearings available
for public review at the EPA, Region 10 offices. The most
frequently made comments were responded to by Metro, with
EPA's assistance, in Metro's Responsiveness Summary, which
was mailed in April 1981 to persons attending the meetings
and hearings, and other persons who had previously indicated
interest. Metro is also preparing a public participation
Compendium documenting all its public participation activities
during facilities planning.
Written Comments on Draft EIS
The Draft EIS review period was initially set for 45
days, and was later extended to 60 days, ending on February
17, 1981. Agencies, organizations, and individuals were
encouraged by EPA to comment on the EIS in writing.
All written comments received on the Draft EIS are
reproduced in Chapter 12 of this Final EIS, together with
EPA responses to each comment. The letters in Chapter 12
include those directly addressed to EPA, as well as those
addressed to Metro and carbon-copied to EPA. General re-
sponses to the most frequently made comments have been pre-
pared, and are presented in the Final EIS FOREWORD.
Schedule for Remaining EIS and Plan Activities
The Final EIS will have a 30-day review period, during
which EPA will receive and consider written comments. The
mailing list for the Final EIS is shown in Table 9-1.
A full public review process has been scheduled for
the Final EIS and final Metro plan. Over 200 copies of the
Final EIS and about 3,000 copies of a summary of the EIS
are being distributed for citizen and agency review and comment,
286
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Table 9-1. Mailing List for Final EIS
FEDERAL AGENCIES
STATE AGENCIES
Mr. Bruce Blanchard, Director
Office of Environmental Project Review
The Interior Building, ROOTI 4256
Washington, IX 20C40
Charles A. Dunn, Field Supervisor
U. S. Fish and Wildlife Service
Ecological Services Division
2625 Paramount Lane, Bldg B-3
Olympia, Washington 98502
Kaylor Martinson, Regional Director
USDOI/Fish and Wildlife Service
Lloyd 500 Building - 1692
500 NE Multnomah Street
Portland, OR 97232
National r'.arine Fisheries
NOAA
IxjDepartment of Commerce
OOP. 0. Box 4332
-JPortland, OR 97208
Leon K. Moraski, District Engineer
Seattle District Corps of Engineers
4735 East Marginal Way South
Seattle, V.'A 98134
Ry Tanino, Environmental Officer
Corn-unity Planning anc Develosment
Department of Housing and Urban Develop.
1321 Second Avenue
Seattle, WA 93101
Office of the Secretary
U. S. Department of Agriculture
Coordinator of Environmental Quality Activities
Washington, DC 20250
Advisory Council on Historic Preservation
Office of Arch and Environmental Preservation
1522 K Street NW, Suite 430
Washington, DC 20005
John D. HcDermott, Director
Office of Review and Compliance
Advisory Council on Historic Preservation
P. 0. Box 25085
Denver, CO 80225
Ernest E. Sligh, Director
Environmental Impact Division, FEA
New Post Office Building
12 and Pennsylvania Avenue NW
Washington, DC 20461
Donald Samuelson, Regional Representative
Department of Transportation, Region 10
Arcade Plaza Building
1321 Second Avenue
Seattle, WA 98101
Frank S. Lisella, Chief
Environmental Affairs Group
Center for Disease Control
Department of Health and Human Services
Atlanta, Georgia 30333
Office of the Governor
State Planning Div. and Community
Assistance Division
100 Insurance Building
Olympia, WA 98504
State of Washington
Department of Game
600 North Capitol Way
Olympia, WA 98501
Attn: Bob Ziegler
Habitat Management Division
Donald W. Moos, Director
State of Washington
Department of Ecology
P. 0. Box 829
Olympia, WA 98504
Mr. Bob McConnick
Mr. Bob Sylvester
State of Washington
Department of Ecology
4350 - 150 NE
Redmond, WA 98052
Barbara Richey
Environmental Review South
State of Washington
Department of Ecology (PV 11)
Olympia, WA 98504
RollandA. Schmitten, Director
State of Washington
Department of Fisheries
General Administration Building, Poem 115
Olympia, WA 98501
Attention: Mary Lou Mills
State of Washington
Ecological Commission
c/o State of Hash. Depart = nt of Ecology
Olympia, WA 98504
Rosemary Walrod, Project Officer
Municipal Division (PV 11)
State of Washington
Department of Ecology
Olympia, WA 98504
Mr. Brian Boyle
Conmissioner of Public Lar.as
State of Washington
Department of Natural Resources
Public Lands-Social Security Building
Olympia, WA 93501
Ms. Jeanne Welch
State of Washington
Historic Preservation Office
111 West 21 Avenue
Olympia, WA 985C4
MEMBERS OF CONGRESS
Honorable Joel Prichard
Congressman, First District
915 Second Avenue
Seattle, M 9E104
Honorable Mike Lowry
Congressman, Seventh District
200 Mill Street
Ren ton, WA 98055
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Table 9-1 (cont'd.)
LOCAL GOVERNMENT
John M. Rose, Chairman
Envi ronn-ental Impact Committee
King Co. Depart' frit of Budget and Pro. Oeve.
King County Courthouse, Room 400
Seattle, HA 9fcl04
Margaret C. Lane, City Manager
Ci ty of Normandy Park
240 S* 200
Noriandy Park, WA 98166
Charles Royer, Mayor
City of Seattle
Municipal Building, 12 Floor
Seattle, UA 96104
Harold Robertson
King County Planning Division
King County Courthouse
Seattle, WA 98104
NJ
00John Nordin
°°SeaUle-King County Health Department
904 Public Safety Building
Seattle, '.'.'A 93104
Raloh Colby
King County Bulding and Land Development
431 King County Courthouse
Seattle, U 98104
Director
Seattle-King County Health Department
Public Safety BuiIding
Seattle, WA 9£104
Linda Stalzer
King County Community Planning
King County Courthouse
Seattle, '..'A 9SK1-!
Di rector
King County Parks and King Co.
Administration Cuihling
Seattle, '.-.« 98104
Sruce Jo.'ii-s
Seattle Engineering
";mi cipal B-jildin.!
Scat-vie, WA 9-504
Jtrry Allen
Office of Policy Evaluation
Executive Department
300. Municipal Building
Scatllo, WA 9;;104
Diana T. White
Environmental Coordinator
City of Bellevue
P. 0. Box 1768
Bellevue, WA 98009
Charles M. McGill, Acting Director
Tacoma-Pierce County Health Department
3629 South D Street
Tacoma, WA 98408
Mary Ann Huhs
Seattle City Council Staff
1)06 Municipal Building
Seattle, WA 98105
Diana Gale
Seattle City Council Staff
1106 Municiapl Building
Seattle, UA 98105
Leroy Jones
King County Office of Ariculture
County Courthouse
Third and James
Seattle, WA 98104
Mary BurMy
King Cou*ty_Growth Management
King County Courthouse
Seattle, WA 98104
Stan McNutt
Ci ty Manager
City of DesMoines
21630 - 11 Avenue South
Destioines, WA 98188
Linda Fitzpatrick, Chairman
Seattle City Planning Commission
400 Yesler Building - 4 Floor
Seattle, WA 98104
Mr. Jim Henry, Manager
DesMoines Sewer District
22626 Seventh Avenue South
DesMoines, WA 98188
Mayor Michael Parker
Ci ty of Tacona
Tacor.a, WA
John Roller, Superintendent
Water Division
City of Tacor.a
Tacoma, WA
LOCAL GOVERNMENT CONT.
Mr. Ron Gehrke
ME Lake Washington Sewer District
18120 - 68 Avenue NE
Bothell, WA 98011
Mrs. Vivian Hill, Manager
Rainier Vista Sewer District
11206 DesMoines Way South
Seattle, WA 98168
Mrs. Sydell Polin, Manager
Ronald Sewer District
17505 Linden Avenue North
Seattle, WA 98133
Mr. Larry Franks
Sahalee Sewer District
2040 - 210 Circle NE
Redmond, UA 98052
Mr. T. J. Matelich, Manager
Val Vue Sewer District
14816 Military Road South
Seattle, WA 98188
Mr. Minford I. Stuckey, Office Manager
East Mercer Island Sewer District
9011 SE 40
Mercer Island, WA 98040
Mr. James McCurdy
Highlands Sewer District
1001 Hoge Building
Seattle, WA 98104
Mr. Mark Spahr, Manager
Water District No. 82
2032 - 212 Avenue SE
Issaquah, WA 98027
Mr. Curtis Bruskland, Manager
Water District Mo. 104
P. 0. Box 244
Woodinville, WA 98072
Daniel Selzler, Superintendent
Water District No. 90
Ren ton, WA 9U055
Pete Beaulieu
Puget Sound Council of GovLrnments
216 First Avenue South
Seattle, WA 93104
Frank Hansche, Director of Public Uoik
Ci ty of Eothell
18305 - 101 HE
Bothell , WA 98011
Ms. Patty Nelson
City Clerk
2901 - 228 SW
Brier, WA 98036
Mr. Jack Crumley
Director of Public Works
City of Issaquah
P. 0. Box "II"
Issaquah, WA 98027
Richard Petit
Clifford Muller
Port of Seattle, Pier 66
Seattle, WA 98104
Mr. Dave Rosenkranz, Director
Pierce County Planning Department
2401 South 35 Street, Room 6
Tacoma, WA 98409
Mr. Jim Billings
Puget Sound Council of Governments
King Subregional Council
216 First Avenue South
Seattle, WA 98104
Mr. George F Sherwin, Jr., Director
Snohomish County Planning iUpartii.siu
County Administration Building
Everett, WA 98201
Mr. Kelly Robinson
Puget Sound Council of Govei mnents
Snohomish Subregional Council
216 First Avenue South
Mr. Sam Macri, Manager
Water District No. 107
5806A - 119 SE
Bellevue, WA 98006
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LOCAL GOVERNMENT COHT.
Table 9-1 tconf d.)
Mr. James Sienther
King County Director of Public Works
King County Adrc.inistratiofi Eldg., Room 900
Seattle, WA 9S104
Mr. Russel David, Manager
Lakehaven Sewer District
31627 First Avenue South
P. 0. Box 304S
Federal Way, WA 98003
Richard Coughton, Acting Director
Public Works
City of Renton
200 Mill Avenue South
Renton, WA 98055
Mr. Ken Pausch, Manager
Sewer Utility
City of Seattle
910 Municipal Building
^Seattle, HA 98104
'•Ir. Ted Uorooto
Director of Public Works
City of Tukwila
6230 - Southcenter Blvd.
Tukwila, WA 9S067
Mr. L. 0. Erikson, Manager
Alderwood Water District
3526 - 15£ SW
Lynnwood, WA 9E036
Mr. Tom E. Earwood, Manager
3ryn "awr-Lakeridje Sewer District
1K02 Rainier Avenue South
Seattle, WA 93173
Mrs. Ethel Hanis, Manager
Cascade Sewer District
1CS2S S£ 17£
P.i.iton, WA 96055
Robert J. Broughton, Manager
.£astgate Se..er district
K^J S£ Eastgate '.. = ;•
"r. Gerry 31 eaves, Vanacer
S?uthr..'est Survjrcan U-.ver District
Mr. Don Wickstrom
Acting Director of Public Works
City of Kent
P. 0. Box 310
Kent, WA 98031
Mr. Larry Larse
Director of Public Service
City of Kirkland
Second and Central Way
Kirkland, WA 98033
Mrs. Ruth Huller
City Administrator
City of Lake Forest Park
17711 Ballinger Way NE
Seattle, WA 98155
Mr. Miles Fuller
Director of Utilities
City of Mercer Island
3505 - 88 Avenue SE
ttercer Island, WA 98040
Mr. Tim Handorff
Utilities Superintendent
City of Pacific
100 Third Avenue SE
Pacific, WA 98047
Fred Herzberg, Director
Public Works
City of Redmond
16570 NE 85
Red::»nd, WA 98052
Mr. Pat Nevins, Director
Public Works
City of Auburn
425 East Main Street
Auburn, WA 98002
Mr. Keith Zettel
Street Utilities Superintendent
402 Uarde Street
Alfjona, WA 98002
Walter Davis, Manager
Utility Oivisi on
City of Bellevue, Department of Utilities
P. C. Sox 97
Eellevje, WA 98009
LOCAL GOVERNMENT CONT.
Richard M. Stredicke, President
Renton City Council
200 Mill Avenue South
Renton, WA 98055
Robert D. Sealey, Superintendent
Highline Public Schools
15675 Ambaum Blvd. SW
Seattle, WA 98166
Curtis Bruskland, Manager
Water District No. 104
P. 0. Box 244
Woodinville, WA 98072
Joseph Tovar, Acting Director
Kirkland Department of Cotr.T.'-nity
210 Main Street .
Kirkland, HA 98033
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Table 9-1 (cont'd.)
ORGANIZATIONS
Bellevue Coalition Community Clubs
c/o v.iria Cain
10-171 lit 17
Cellev-je, I.\ 9S004
Federal '.lay Community Council
29-511 - 13 Avenue SW
Federal Way, WA 9E003
Bear Creek Valley Association
c/o Carl Sheve
1454?: Bear Creek Road
Woodinville, '.vA 98072
Cougar Mountain Residential Association
C/o Ji
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Table 9-1 (cont'd.)
CITIZENS
V0
Mr. Norman Zenk
8650 - 32 Avenue SH
Seattle, UA 93126
Jay LaVassan
702 West Cremona
Seattle, UA 98119
Robert A. Nova, President
King County Hater District *82
19604 SE 31 Place
Issaquah, WA 98027
Mr. 4 Mrs. A. I. Mourn
12801 Standring Lane SW
Seattle, WA 98146
Mr. 4 Mrs. Gideon Kramer
2401 SU 172
Seattle, UA 98166
Mary Ellen Hamblin
13025 - 138 Avenue SE
Renton, KA 98055
Ray Pederson
211 SE 196 Place
Seattle, V.'A 98166
f-'.r. J Mrs. Henry Wheeler
13356 - 35 Avenue South
Seattle, WA 98163
Nancy Hahn
12221 Shorewood Drive SU
Seattle, WA 98146
K. Selivanoff Parker
1500J - 24 SW
Seattle, '*A 98166
Greg Schuler
2106 - 47 Avenue SW
Seattle, '..'A 98166
Mr. U. I!. Cook
Box '291
Seattle, '*'A 9313-
,Vr. L Mrs. Vernvf
2TVj sw ir.6 stivL-t
Secittlo, .!A 'jolcS
Mrs. Karl H. Klopfenstein
3750 SW 171 Street
Seattle, HA 98166
Mr. 4 Mrs. Myron B. Savage
16303 Maplewild Avenue SU
Seattle, HA 98166
Wayne J. E. Lann
15911 SE 177 Street
Renton, WA 98055
Mr. 4 Mrs. Pierre Matthews
2651 SW 164 Place
Seattle, WA 98166
Versie and Warren Vaupel
400 Cedar Avenue South
Renton, UA 98055
Dr. Eugene Helen
Department of Civil Engineering
University of Washington
305 More Hall, FX-10
Seattle, WA 98195
A. Noel Nelson
3126 SH 172
Seattle, WA 98166
V. Selivanoff
14617 - 25 SW
Seattle, WA 98166
Paula E. Clark
16422 - 8 Avenue SW
Seattle, WA 98166
Robin Rolstad
4613 - 48 Avenue South
Seattle, UA 98118
Donald A. Mass
5000 SW Stevens
Seattle, WA 98166
Jeanne L. Snell
Route 1 Box 210
Burton, WA 9EG13
CITIZENS CONT.
Thomas J. Taafee
417 SW 152
Seattle, WA 98166
Anna M. Bruce
15620 - 21 SH
Seattle, UA 98166
Louis Sraithmeyer
12009 - 30 Avenue SW
Seattle, WA 98146
Eric Denton
2123 SW 172
Seattle, WA
98166
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Metro has scheduled a series of public informational
meetings on the final plan at the following dates and locations
Thursday, August 20
Monday, August 24
Tuesday, August 25
Wednesday, August 26
Thursday, August 27
Wednesday, September 2
- Bothell City Council Chambers
- Ober Activity Center, Vashon
Island
- Metro Fourth Floor Conference
Room, Seattle
- Highline High School Cafetorium
- Puget Sound Power and Light
Auditorium, Renton
- Alki Congregational Church
EPA and Metro will hold joint public hearings on the
Final EIS and final plan at the following dates and locations:
Tuesday, September 8
Wednesday, September 9
Thursday, September 10 -
Puget Sound Power and Light
Auditorium, Bellevue
Alki Congregational Church
Highline High School Cafetorium
Individuals or groups that wish to comment in writing
on the Final EIS may forward written comments to:
U. S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Attention: Roger Mochnick M/S 443
Comments should be sent by the close of the 30-day comment
period on September 14. All verbal and written comments
will be considered by EPA in reaching its final decision
following the close of the comment period.
292
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Chapter 10
LIST OF EIS PREPARERS
Jones & Stokes Associates, Inc., Sacramento, CA
Charles R. Hazel. B,S., M.S., and PhD., Fisheries
Biology. Formerly with California Department of Fish and
Game as Director of Water Pollution Control Laboratory. As
vice-president of Jones & Stokes Associates, has managed
numerous environmental studies and reports and served as
expert consultant in fisheries and water quality ecology.
Area of EIS Responsibility. Project management.
Albert Herson. B.A., and M.A. , Psychology, M.A. Urban
Planning. As staff environmental planner, responsibilities
are project management and preparation of planning studies,
specializing in land use planning, growth policy, and public
service systems. Formerly water quality planner for Southern
California Association of Governments. Member, American
Institute of Certified Planners (AICP).
Area of EIS Responsibility. Project coordinator;
growth, land use, and secondary impact analysis.
Thomas C. Wegge. B.A., Urban Studies, M.S., Environ-
mental Economics. Environmental economist specializing in
socio-economic impacts of land use changes, cost-benefit
and risk analysis, and energy impact assessment.
Area of EIS Responsibility. Growth, land use, and
secondary impact analysis.
Douglas P. Albin. A.B., Zoology, M.S., Fisheries.
Formerly with California State Water Resources Control Board,
where projects included instream flow requirement program.
Specialty areas are anadromous fisheries and freshwater
ecology of coastal streams.
Area of EIS Responsibility. Surface water quality,
biological and fisheries impact analysis.
Paul Wisheropp. B.S., Environmental Engineering,
B.S., Water Resources Management. Environmental engineer
specializing in quantitative hydrologic and water quality
investigations.
293
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Area of EIS Responsibility. Surface water quality impact
analysis.
Jeffrey D. Civian. B.S., Renewable National Resources.
Environmental specialist experienced in air quality and noise
analyses with emphasis on line source modeling and emission
forecast development.
Area of EIS Responsibility. Air quality impact analysis.
Douglas Updike. B.A. and M.A., Biology. Staff biologist
with previous experience in EIS coordination and production.
Area of EIS Responsibility. Technical coordination.
Patricia S. French. B.A., French, M.L.S., Library and
Information Studies. Staff librarian responsible for acquisi-
tion and organization of reference documents. Conducts litera-
ture studies and compiles bibliographies, and assists in
technical editing.
Area of EIS Responsibility. Preparation of reference
listing and index.
Clean Water Consultants, Santa Ana, CA
William Wittenberg. P.E., B.S., Civil and Environmental
Engineering. Past projects with CWC include assessing impacts
of water quality on consumer costs and studies developing
processes for water and wastewater treatment. Formerly with
Orange County Water District, where responsibilities included
technical support for a 15 MGD advanced wastewater treatment
plant.
Area of EIS Responsibility. Alternatives description
and cost and resource impact analysis.
Gruen Gruen + Associates, San Francisco, CA
Roberta M. Mundie. B.A., Social Sciences, Master of
City Planning. Held positions with several public planning
agencies; 8 years experience in socio-economic impact analysis
and forecasting with consulting firm, with emphasis on land
use, land development and related issues. Supervises major
socio-economic and land use projects for Gruen Gruen + Associates,
Area of EIS Responsibility. Population projections
and economic/fiscal impact analysis.
294
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Suzanne Lampert. A.B., Urban Studies, Master of Public
Affairs and Urban Planning. Experience with both public
agencies and private firms in environmental analysis (es-
pecially socio-economic) and general planning. In three
years with Gruen Gruen + Associates, has focused on the
economic and fiscal impacts of public plans and policies.
Area of EIS Responsibility. Population projections
and economic/fiscalimpactanalysis.
H. Esmaili & Associates, Inc., Berkeley, CA
Houshang Esmaili. B.S., Agricultural Engineering,
M.S., Irrigation Science, Dr. Eng., Water Resources Engi-
neering. Twelve years experience as a consulting civil and
agricultural engineer. As president of H. Esmaili & Associates,
Inc., has supervised the conduct of over 20 engineering projects
and environmental studies.
Area of EIS Responsibility. Soils and groundwater impact
analysis.
Roger D. Abraham. B.S., Soils and Plant Nutrition,
M.S., Soil Science. Experienced soil scientist whose previous
projects with HEA include agricultural nonpoint source assess-
ments, soil resource inventory, and feasibility studies of
agricultural reuse of municipal wastewater.
Area of EIS Responsibility. Soils and groundwater impact
analysis.
Robert H. Enkoboll. A.B., Geology, M.S., Earth Sciences.
Earth scientist whose previous projects include sampling,
analyzing, and interpreting channel sands to determine source
areas and relative sediment yields in hydrologically-complex
watersheds.
Area of EIS Responsibility. Soils and groundwater impact
analysis.
Barry Hecht. A.B., Geology, Geography/Planning, M.A.,
Geography. Responsible for a wide range of geologic and
hydrologic investigations. Previous projects include a variety
of sediment transport studies, analysis of nonpoint source
groundwater pollution controls, and assessments of groundwater
impacts of land application of effluent and sludge.
Area of EIS Responsibility. Soils and groundwater impact
analysis.
295
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Kahn/Mortimer Associates, Seattle, WA
Vivian Kahn. B.A., English Literature. Experienced
Seattle-area planner whose recent projects include 1-90
corridor study and fiscal impact analysis of proposed King
County comprehensive plan. Formerly Chief of Community
Assistance, California Office of Planning and Research.
Member, American Institute of Certified Planners.
Area of EIS Responsibility. Assessment of local planning
consistency.
Hall and Associates, Seattle, WA
Susan Hall. B.A., President of Hall and Associates, a
public participation consulting firm. Experience includes
drafting of public participation policies for federal
agencies, and designing and managing public participation
programs.
Area of EIS Responsibility. Preparation of public
summary and assistance in conducting public workshops.
University of Washington, Office of Public
Archeology, Seattle, WA
Hal K. Kennedy. B.A., Anthropology, M.A., Anthropology.
Experienced cultural resources researcher with extensive
field experience in the Pacific Northwest.
Area of EIS Responsibility. Cultural resources impact
assessment.
University of Washington, Fisheries Research Institute,
Seattle, WA
Dr. Quentin J. Stober. B.S. and M.S., Fish and Wildlife
Management, PhD., Aquatic Ecology. Currently research pro-
fessor, Fisheries Research Institute. Research interests
include aquatic ecology, impacts of stream flow alteration,
and impacts of wastewater effluent discharges.
Area of EIS Responsibility. Review of fisheries
impact analysis.
296
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G-oIogical Drafting Service, Sacramento, CA
Steve Fleming. Extensive experience preparing maps,
charts, and illustrations for technical reports and documents.
Additional experience preparing cartoons and illustrations
for various reports and publications.
Area of EIS Responsibility. Report graphics.
297
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Chapter 11
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. 1980. Green-Duwamish River basin instream resources
protection program, including proposed administrative
rules, and supplemental environmental impact statement.
Prepared by Water Resources Policy Development Section.
Olympia.
Washington Dept. of Fisheries. 1977. Washington state sport
catch, 1977.
. 1978. The 1977 Washington trawl landings by Pacific
Marine Fisheries Council and state bottom fish statistical
areas. Progress rep. no. 76.
1978. Puget Sound public shellfish sites.
Olympia. 31 pp.
1979. Puget Sound commercial net fishery data
report for 1977. Progress rept. no. 85.
313
-------
Washington Office of Financial Management. 1979. State of
Washington population trends. Olympia.
Waterman, T. T. 1922. The geographical names by the Indians
of the Pacific Coast. Geographical Rev.:175-194.
Welch, E. B., and W. T. Trial. 1979. Ammonia toxicity affected
by pH and nitrification in the Duwamish River estuary.
Draft report to Brown & Caldwell, Seattle.
Western Washington Agricultural Research and Extension Center.
1977. Utilization of dewatered sewage sludge on agricultural
land. Metro sludge utilization research rep. Municipality
of Metropolitan Seattle.
Williams, R. C. 1968. Water resources of King County, Washing-
ton. U.S. Geological Survey water supply paper. 1852.
Williams, R. W., R. M. Laramie, and J. J. Ames. 1975. A catalog
of Washington streams and salmon utilization, vol. 1: Puget
Sound region. Washington State Dept. of Fisheries.
Willingham, et al. 1979. Ammonia: American Fisheries
Society, a review of the EPA Red Book: Quality Criteria
for Water.
Wydowski, R. S. 1972. Checklist of fishes occurring in the Lake
Washington drainage. Interim rep. no. 34. Coniferous Forest
Biome, University of Washington, Seattle.
Yake, W. E. 1980. The impact of effluent from the Renton waste-
water treatment plant on the dissolved oxygen regimen, of the
lower Green/Duwamish River. Water and Wastewater Monitoring
Section, Washington Dept. of Ecology, Olympia.
314
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Chapter 12
WRITTEN COMMENTS RECEIVED ON
DRAFT EIS AND RESPONSES TO COMMENTS
Introduction
The public comment period on the Draft EIS lasted from
December 19, 1980 to February 17, 1981; written comments
were accepted by EPA for several days after the February 17,
1981 closing date. During the review period, EPA received
written comments on the EIS from five federal agencies, five
state agencies, nine regional or local agencies, seven organi-
zations, and 39 citizens. Some of the agencies responded
twice or more in writing, and some of the citizen letters
were signed by more than one citizen. Included in these
totals are letters addressed to Metro, and carbon-copied
to EPA. EPA also received petitions with about 2,000 signa-
tures from residents of the Burien, Highline, and Vashon
Island areas, opposing an outfall in the Three Tree Point
area.
The issues raised in these letters can be classified
into several broad groups: water quality issues, wastewater
management planning issues, sensitive areas issues, con-
struction and neighborhood impacts issues, cost issues, and
EPA decision-making issues. General answers to the most
frequently raised comments are presented in the FOREWORD
to this EIS.
This chapter presents all written comments received
by EPA on the Draft EIS, and responses to each comment letter.
For each comment, the letter is first presented, with numbers
in the margin indicating the specific statements responded
to; responses to each of the statements are then grouped
following each letter.
315
-------
FEDERAL AGENCIES
316
-------
Sol
Con»n«tion
Servk:e
Room 360 U.S. Courthouse
Spokane, Washington 99201
December 31 . 1980
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
We have reviewed your draft environmental impact statement for Wastewater
Management Plan for the Lake Washington/Green River Basins. It would
appear the concerns of the Soil Conservation Service are met, and we have
no comments to offer at this time.
Sincerely,
Response to SCS Letter of December 31, 1980
1. No response required.
£
A. BROWN
State Conservationist
'-/
BECEIVED
JAN 5 P-t"'
SCS-AS-1
10-79
-------
Advisory
Council On
Historic
Preservation
1522 K Slreol. NW
Washington. DC 20005
Reply lo.
Lake Plaza Soulh. Suite 616
44 Union Boulevard
Lakewood. CO 80228
Page 2
Mr. Roger K. Mochnick
Wastewater Management Plan for
Lake Washington and the Green
River Basins
January I1*, 1981
January 111, 1981
Mr. Roger K. Mochnick M/S UU3
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
Thank you for your request of December 2, 1980, for comments on the
draft environmental statement for the wasteuater treatment plan for the
Lake Washington and Green River Basins in Washington. Pursuant to
Section 102(2)(c) of the National Environmental Policy Act of 1969
and the Council's regulations, "Protection of Historic and Cultural
Properties" (36 CFE Part 800), we have determined that your draft
environmental statement does not contain sufficient information
concerning historic and cultural properties for review purposes.
Please furnish the following data indicating compliance with Section
106 of the National Historic Preservation Act of 1969 (l6 U.S.C. Sec.
liJOf, as amended, 90 Stat. 1320). The environmental statement must
demonstrate that either of the following conditions exist:
1. No properties included in, that may be eligible for inclusion
in, or that have been determined on the authority of the Secretary
of the Interior to be 'eligible for inclusion in the National
Register of Historic Places are located within the area of
environmental impact, and the underaking will not affect any
such property. In making this determination, the Council
requires:
- evidence that you have consulted the latest edition of the
National Register (Federal Register:, March 18, 1980, and its
monthly supplements);
- evidence of an effort to ensure the identification of properties
eligible for inclusion in the National Register, including
evidence of contact with the State Historic Preservation
Officer whose comments should be included in the final
environmental statement. The State Historic Preservation
Officer for Washington is Mr. Louis Guzzo.
2. Properties included in, that may be eligible for inclusion in,
or that have been determined on the authority of the Secretary
of the Interior to be eligible for inclusion in the national
Register of Historic Places are located within the area of
environmental impact, and the undertaking will or will not affect
any such property. In cases where there will be an effect, the
final environmental impact statement should contain evidence
of compliance with Section 106 of the National Historic Preserva'.ior.
Act through the Council's regulations.
If you have any questions, please call Marjorie Ingle at (303) 2l
an FTS number.
Sincerely,
jkcAjuv^
Louis S. Wall
Chief, Western Divison"
of Project Review
-------
Response to AOHP Letter of January 14, 1-961
1. The latest edition of the National Register of Historic
Places has been consulted, and the list includes a number of
National Register sites within the study area. However,
none is near the Renton treatment plant or the tunnel/
outfall route to Puget Sound.
2. The State Historic Preservation Officer (SHPO) has been
consulted, and in a January 7, 1981 letter to EPA (presented
later in this chapter), the SHPO indicates concurrence with
measures to identify cultural resources and mitigate antici-
pated impacts described in the EIS.
3. EPA has determined that none of the National Register
sites within the study area will be directly affected by
the proposed project. None of the facilities proposed under
the final plan recommended program (improvements at the Renton
treatment plant site, tunnel/outfall to Puget Sound) involves
construction near a National Register site.
-------
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Heilih Sarvic«
Onion for Diioise Control
Atlanta. Georgia 30333
(604) 262-6649
January 28. 1981
Mr. Roger K. Mochnick
Environmental Evaluation Branch, M/S 443
U.S. Environmental Pro tec tion Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
We have reviewed the Draft Environmental Impact Statement (EIS) for the
Wastewater J-Janagement Plan for the Lake Washington/Green River Basins. We
are responding on behalf of the U.S. Public Health Service and are offering
the following comments for your consideration in preparing the final document.
In general, we have no major objections to the preferred action concerning
collection system changes, Renton treatment plant expansion, solids handling
fac11ities, and a tunnel and outfall to Puget Sound.
According to the EIS, the Renton treatment plant lies next to the Green/Duwamish
River. Fill is required to raise elevations on the undeveloped part of the
plant site from 16 feet to between 26 and 34 feet. While it is indicated that
the plant site will receive adequate protection from floods, please explain if
the fill is to be placed within a 100-year flood plain and whether 100-year
flood levels will be altered upstream of the treatment site.
We have some concerns regarding the Redmond Connection Emergency Bypass. We
understand that this bypass is designed to operate in the event of a failure
at the Totem Lake pumping station. The probability of an emergency bypass
occurring should be better described. The potential health hazards from any
discharge of untreated sewage into the Sammamish River should also be addressed.
In particular, the potential impact upon water quality and food fish resources
in Sannamish River and its receiving waters should be discussed.
With regard to the first and second "grant conditions for secondary impacts'1
(page 227), the local importance of agricultural, flood plain, or wetland
areas has not been acknowledged. An analysis by local agencies of the impacts
upon these areas and of practicable alternatives may not necessarily be protec-
tive by itself. How do local regulations or laws for protection of these areas
compare to Executive Orders 11988 and 11990 on flood plain and wetlands protec-
tion and Federal policies on agricultural lands?
Page 2 - Mr. Roger K. Mochnick
We appreciate the opportunity to review this Draft EIS. Please send us one
copy of the final document when It becomes available. Should you have any
questions about our comments, please contact Mr. Robert Kay of my staff at
(404) 262-6649.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
®
FEB * 1861
BWUUMXTH.
lfc«OJ
-------
Response to DHHS Letter of January 28, 1981
1. The Federal Emergency Management Agency (FEMA) is cur-
rently remapping the Green River floodplain in response to
new regulations; it is not known whether the Renton treatment
plant site will be shown as being within the 100-year flood-
plain on the new map. The required filling of the treatment
plant site should have no major effect on 100-year flood
levels upstream of the site.
2. The pipelines and pump stations called for in the
Redmond and Hollywood/North Creek connections would be capable
of handling peak flows under normal operating conditions.
Pump stations are designed with redundant units so that routine
maintenance and repair can take place without interruption
in service. An interruption in service could occur in the
event of a power outage. Because this is a possibility,
provisions are made for reserve power generation capacity
at pump stations to keep them in operation. This may be
in the form of diesel powered generation facilities located
at the pump station site or portable units. Metro currently
utilizes both of these types of systems in its existing pump
stations. With these backup systems the possiblity of an
emergency overflow is extremely unlikely. The impacts of
such an event have been described in more detail in Chapter 6
of the EIS.
3. See General Response Number 6. Metro and local govern-
ment programs described in Chapter 7 of the EIS have recog-
nized the importance of agricultural lands, wetlands, and
floodplains. Requiring further analysis to be performed
for interceptor sewers connecting to the Renton plant does
not guarantee the protection of agricultural lands and sensi-
tive areas from development, but would encourage careful
analysis of impacts, alternatives and mitigation measures
prior to decision-making; this is the emphasis of federal
policies for these areas.
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Ecological Services
2625 Parkrnont Lane, S.H., Bldg. B-3
Olympia, Washington 98502
February 17, 1981
Roger K. Mochnick M/S 413
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
We have reviewed the draft environmental impact statement concerning the
Wastewater Management Plan for the Lake Washington/Green River Basins dated
December 1980. Based on our review of the above document, we support the
concept of alte-native A-5, which would provide centralized processing at the
Renton plant with a discharge of secondary effluent to Puget Sound off
Alki Point. While we believe this alternative is the best in solving future
adverse water quality impacts in the Green/Duwamish River, our agency is
extremely concerned about potential impacts to riverine habitat and losses of
wetlands, floodplains, and agricultural lands associated with the construction
of the components of the collection system and tunnel/outfall .
It was noted in our review of the EIS document that there were major impacts
to fish and wildlife resources with the various components of the preferred
alternative. These are summarized below:
1. Redmond Connection (pages 91-95)
The 12,500-foot-long alignment would impact agricultural lands.
". . . portions of the alignment will be within the seismic and erosion
hazard areas within the 100-year floodplain of the Sammamish River.
Furthermore, construction will be necessary within the riverbed of the
Sammamish River at one point."
2. North Creek/Hollywood Connection (page 95)
"Much of the proposed North Creek/Hollywood connection will traverse
agricultural land from Uoodinville south to the existing Hollywood
pumping station at N.E. 124th Street ... The alignment would pass
through areas considered sensitive by King County. Host of the alignment
from Bothell south to N.E. 124th Street would be within a Class III
seismic hazard area and the 100-year floodplain of the Sammamish River
and Bear Creek. The alignment would require one strea
Creek) and construction through several wetlands just sound (sic) of
Uoodinville."
3. Alternative Route E (East Duwamlsh) - Effluent Discharge Route for
Alki Point (pages 107-108)
The river crossing of this alternative would be near Kellogg Island. It
should be noted that Kellogg Island is the last tract of undeveloped
wildlife habitat located in a highly industrialized area. The area is
used by a variety of migratory birds. The island has also been recently
listed in a U.S. Fish and Wildlife Service publication entitled
"Important Fish and Wildlife Habitats of Washington". We recommend that
an alternate location of a river crossing be found in order to prevent
disruption of this significant habitat.
4. Impacts of Redmond Connection Emergency Bypass (pages 127-129)
"One feature of the Redmond connection, proposed as part of the preferred
program, could adversely affect water quality. This Is an emergency
bypass from the York pump station discharging to the Sammamish River.
The emergency bypass would be designed to operate in the event of failure
at the Totem Lake pumping station, which is considered by Metro to be an
event of renote probability. Sewage &ould be bypassed to the Sammamish
River in such an event ... A substantial inflow of sewage could cause
mortality to invertebrate and fish populations downstream of the
Hollywood pump station."
We believe these four issues identified above should be studied in greater
detail. Due to the Impacts to wetlands, floodplains, and agricultural land,
more alternative routes should be explored for the Redmond connection,
North Creek/Hollywood connection, and the effluent discharge route for Alki
Point. The development of a full array of alternative routes is necessary if
your agency is going to fully comply with Executive Order 11990, Protection of
Wetlands, and Executive Order 11998, Floodplain Management. In addition, an
emergency generation source should be found for the Totem Lake pumping station
in order to prevent a major fish kill in the Sammamish River.
He also want to call your attention to Washington Department of Game's letter
dated February 3, 1981 (copy attached), which provided comments relative to
this proposed project. We agree with their comments made under item 10, State
Environmental Policy Act, page 5. In light of these comments, we recommend
that if EPA funds are used in the design and/or construction of wastewater
facilities for the Lake Washington/Green River Basins, then tetro be required
to conduct detailed assessments of impacts to sensitive areas (riverine
habitat and wetlands, floodplains, and agricultural lands) in future SEPA
EIS's for interceptor sewers connecting to the Renton plant. These EIS's
should focus on location of specific impacts, alternative plans, and
mitigation measures.
FEB 20 1981
ENVIRONMENTS EVALUATION
-------
We appreciate the opportunity to review this document. If you have any
additional questions, please contact Martin Kenney, of my staff, at 753-9440.
Sincerely,
Charles A. Dunn
Field Supervisor
Attachment
cc: WDG
WDF
UDE
BIA
NKFS
Mjckleshoot Indian Tribe
Response to USFWS Letter of February 7, 1981
1. See General Response Number 6.
2. See General Response Number 2 to Department of Human
and Health Services letter.
3. EPA intends to require such assessments as a grant condi-
tion for the Metro plan.
-------
United States Department of the Interior
I IS1I AM) \\II.DI.IH; SKRVICK
Ecological Services
2625 Parkmont Lane, S.U., Bldg. B-3
Olympia, Uashington 98502
2, 1981
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
In a letter dated February 17, 1981, our agency commented on the draft
environmental impact statement concerning the Wastewater Management Plan for
the Lake Washington/Green River Basins. Since the submittal of our comments,
we have reviewed the implications of the preferred alternative in greater
detail. "Ms review was facilitated by a February 18, 1981, meeting held to
review water quality studies of the Duwamish River as related to the U.S. Army
Corps of Engineers' proposed deepening and widening navigation project. At
this meeting, it was pointed out that the Renton Treatment Plant contributes
25 percent of the flow in the Duwamish River during the low-flow months of
August and September. We understand that the percentage during the low-flow
months would be substantially higher by the year 2000.
While our agency continues to support the concept of alternative A-5, we
believe the final EIS should address the following issues:
1. What is the effect of removing the Renton Treatment Plant discharge from
the Green-Duwamish River? We are particularly concerned about reduced
flows and what impacts they could have on salmonids during the following
periods:
a. Upstream migration of adults.
b. Outmigration of juveniles.
c. Low-flow months.
2. Does your agency and Metro believe the flows established by the
Department of Ecology (DOE) under their June 1980 Green-Duwamish River
Basin Instream Resources Protection Program can be met under the
preferred alternative?
3. If DOE's minimum instream flows cannot be met, what does this flow
reduction mean in terns of salmonid spawning and rearing, and adult,
juvenile, and fry habitat? If anticipated flows under the preferred
alternative are projected to be different than DOE's established minimum
instream flows, then we believe the project should quantify fish habitat
at various life stages under different flow regimes. One methodology
which evaluates fish habitat at various flow regimes is the Service's
incremental flow methodology, which is described in the Service's
publication entitled, "Hydraulic Simulation in Instream Flow Studies:
Theory and Techniques".
In summary, these comments are to supplement our original comments made on
February 17. We believe these additional comments raise important concerns
relative to fish and wildlife which must be addressed in the final EIS. In
addition, we request that these comments be included in the final EIS.
If you have any questions, please contact Martin Kenney, of my staff, at
(FTS) 434-9440 or commercial 753-9440.
Sincerely,
Charles A. Dunn
Field Supervisor
cc: EPA (Partridge)
WDG
UDF
WDE
BIA
NMFS, Seattle
Muckleshoot Indian Tribe
-------
Response to U. S. Fish and Wildlife Service Letter of March 2,
1981
1. See General Response Number 1 to the following letter
from the U. S. Army Corps of Engineers. Since DOE minimum
flows are for 300 cfs measured at Auburn, and since the Renton
treatment plant discharges to the Duwamish below Auburn, the
discharge does not affect achievement of minimum flows at
Auburn. DOE did not include the Renton discharge in the
300 cfs guideline. If the 300 cfs minimum flow is not met
at certain times, and the Renton discharge is diverted from
the Duwamish River, that discharge would not be available
to compensate for the shortfall below 300 cfs downstream
from the treatment plant.
-------
DEPARTMENT OF THE ARMY
SEATTLE DISTRICT. CORPS OF ENGINEERS
P O. BOX C-3733
27FEB 1981
NPSEN-PL-ER
Roger K. Mochnick
Environmental Evaluation Branch
U.S. Environmental Protection
Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
We have reviewed the draft environmental impact statement on the Wastewater
Management: Plan for Lake Washington/Green River Basins, Washington, with
respect to the U.S. Anny Corps of Engineers' areas of responsibility for
flood control, navigation, and regulatory functions. Our comments are
at t ached as inclosure 1.
Thank you for the opportunity to review thifl statement. If you have any
questions, please contact Dr. Steven F. Dice of my staff, at telephone
(206) 764-3624.
Sincerely,
1 Incl
As stated
'Colonel, Corps of Engineers
District Engineer
MAR
£NVIROIW4£MT*L EVALUATION
BRANCH
NPSEN-PL-ER 13 February 1981
COMMENTS: Draft Environmental I a pact Statement (DEIS), Waotewater Man-
agement Plan for the Lake Washington/Green River Basin
1. Throughout the DEIS, reference is made to Was
Ecology (1980) minimun flow rules which call for
300 cubic feet per second (c.f.a.). As clarified
meeting attended by the Corps of Engineers, Metro
may be i oa ppropri ate as a pi arming or impact asse
fflinimim flow constraints are designed to preclude
would cause flow at Auburn to fall below 300 c.f.
presently falls below 300 c.f.s. in most years.
will probably continue to fall below 300 c.f.s. b
constraint s wil1 not affect previously existing d
conservation storage in Howard A. Hanson reservoi
increase flow suppl ement 9 to assure 300 c.f.s. at
.hington Department of
sunner flows of
at a 4 February 1981
, and EPA, this figure
asm en t criteria. DOE
new diversion which
, a . Ho we ve r , f 1 ow
In the future, flows
•ecause DOE minimum flow
liver s ion s . Existing
r is insufficient to
Auburn .
2. The DEIS does not address potential interactions with the Seattle
Diatri ct' a navi gat ion and f lood control studies for the Green-Duwamish
system. Par ti cular at ter tion should be paid to cunul ati ve a ad secondary
effects on water quality, fisheries, and land use (especially future
growth). Primary effects are generally well dealt with; however, it
appears that the secondary and tertiary effects of Metro' s proposal , in
concert with the actions of other agencies and local governments, may be
of more significance than the immediate effects.
3. The Seattle District has recently completed a water quality study in
the Duwamish estuary that considers the possibility of removing Renton
sewage treatment plant effluent frcm the river. A copy of this report
has been sent to Ms. Lloyd Eagan of Metro's staff.
4. Because of the potential for future water quality problems in the
Dvwamish Riwr Estuary as a result of diversion of treated waters to
Puget Sound, we suggest that consideration be given to modifying the
selected al temative as described in the following paragraphs.
Presently, the Renton Sewage Treatment Plant diverts treated waters to
the Green/Duwamish Rivers at a peak rate exceeding 40 million gallons
daily. During low flow periods, these discharges provide a benefit by
increasing total volune and velocities in the river. This procedure
minimizes the potential for water quality problems associated with lower
flows (agal blooms, dissolved oxygen decreases, etc.) and attend ant
potential impacts to f isheri es resources. As there is little likelihood_
that low flows within the basin can be substantially increased on a sus-
tained basis by a change in operation of Howard A. Hanson Dam, we sug-
gest that consideration be given to retention of some capacity for
"advanced secondary treatment with nitrification at the expanded Renton
Plant. During low-flow periods or during "drought" years, these treated
waters could be directed to the Green—Duwamish system, as needed,
isai
iLSlJC EVAiii"!*'1
-------
through the existing outfall. During other periods of the year, secon-
dary treated waters would be mixed with lesser treated waters and piped
to Alki or Point Pulley for final treatment and discharge to Puget Sound.
Although we realize additional costs may have to be absorbed for systems
modifications at the plant site and for operation and maintenance of a
dual pipe system to at least the Green/Duwamish outfall, further anal-
ysis may show this modification to be cost effective when considering
the potential danger to fisheries resources because of inadequate flows
to abate water quality problems.
5. Page 7, paragraph titled "Clean Water Act." This section should
also refer to Section 404 of the Clean Water Act. Section 404 discusses
Department of the Arny permit requirements concerning the discharge of
dredged or fill materials into waters of the United States and on adja-
cent wetlands.
Page 11, paragraph titled "Corps of Engineers.' This section should
also ref»r to Corps of Engineers responsibility to issue permits under
Section lu of the River and Harbor Act of March 3, 1899 for the per-
formance of any work in navigable waters of the United States.
6. Page 29 and table 2-4 on page X. The latest population data shown
is for 1970 which is now out of date. State population data is
available for 1980 and should be used.
7. Page 144, table 5-4, item 8 under "Additional Measures Available"
credits interim river flow augmentation with high potential for reduc-
tion of the current ammonia 1oad. However, the storage available in
Howard A. Hanson Dam is conanitted to the maintaining of a discharge for
fishery and no additional water is available for increased augmenta1-
tion. This could be significant since Metro reports that few of the
•eas ures in and of themselves solve the problem of ammonia, but that
combinations can adequately protect the river's fishery resource through
the construction period.
(6)
Response to U. S. Army Corps of Engineers Letter of February 13,
1981
1. The EIS states in Chapter 6 that actual flows fall below
300 cfs. In the analysis of effects of increased Tacoraa
diversions, the EIS acknowledges that DOE minimum flows apply
to future, not existing, diversions.
2. Analyses of proposed Corps dredging, the SCS drainage
project, and increased Tacoma diversions were added to
Chapter 6 of the Final EIS. The Final EIS contains an exten-
sive analysis (Chapter 7) of the secondary impacts of the
project.
3. The results of the studv have been integrated into the
Final EIS.
4a. See General Response Nuiu.'jer 3.
4b. A seasonal nitrification alternative was considered
by Metro, but was rejected because of the extreme opera-
tional difficulties of turning on and off the complex bio-
logical processes involved ir. nitrification.
5. This correction has been made in the Final EIS.
6. This correction has been made in the Final EIS.
7. The 1980 census data would increase the study area 1980
population by about 32,000. This is not considered to be
a significant enough difference to vary the capacity planned
for at the Renton plant.
8. Comment noted. Metro has consulted with Washington
State Department of Fisheries regarding timing of the fishery
maintenance flow from the reservoir.
-------
STATE AGENCIES
328
-------
STATE OF
WASHINGTON
Day LeeRw
Gouemor
OFFICE OF ARCHAEOLOGY AND HISTORIC PRESERVATION
E. MS KL 11. (
Response to SHPO Letter of January 7, 1981
1. No response required.
January 7, 1981
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
In reply refer to: 186-F-EPA-01
Re: yastewater Management Plan for the
Lake Washington/Green River Basins
Dear Mr. Mochnick:
A staff review has been completed of your draft environmental inpact
statement. The project was discussed previously by this office with
Mr. Craig Partridge of your staff. He concur with measures proposed to
identify cultural resources and aitigate anticipated impacts to such
resources as may be present.
Thank you for this opportunity to comment.
Sincerely,
JEANNE M. WELCH, Deputy State
Historic Preservation Officer
db
Sheilai
HHCEIVED
.i-i.N 8 PECT)
-------
\ STATE OF
WASHINGTON
DEPARTMENT OF TRANSPORTATION
Mmmirat^i BuJdmg. Otympw. Washington 96504
January 27, 1981
Response to DOT Letter of January 27, 1981
1. No response required.
Mr. Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
U.S. Environinental Protection Agency
Wastewater Management Plan
Lake Washington/Green River Basins
Draft Environmental Impact Statement
Dear Mr. Mochnick:
We have reviewed the subject document and have no comments to
offer regarding the proposal.
Thank you for the opportunity to review this information.
(D
RSN:kls
JB/WBH
cc: J. D. Zirkle/T. R. Burke
Sincerely,
ROBERT S. NIELSEN
Assistant Secretary for Public
Transportation and Planning
'JOSEPH BELL. Manager
Planning Implementation and
Environmental Policy
-------
STATE OF
WASHINGTON
John Spellraan
Governor
DEPARTMENT OF GAME
600 North C«*ol W«v GJ II Ch.iwA U'A 9U<
February 3, 1981
Hr. Robert K. Hochnick, MS/443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
DRAFT ENVIRONMENTAL IMPACT STATEMENT:
Management Plan for the Lake Washington/Green
River Basins, King County
Mr. Mochnick:
Your document was reviewed by our staff as requested; our comnents follow.
Your document does show an understanding of impacts from projects similar to
your sewering plan, but many of the statements are confusing and appear to
contradict, so it is not clear what the impacts would be on the public's
fish and wildlife resources from this project. Our questions follow.
1. We wonder if your preferred plan would meet Federal Consistency
Requirements under the Coastal Zone Management Act. The Coastal
Zone includes all the territory in King and Snohoraish counties.
Not only would your project have a direct impact on marine waters,
but secondary impacts (urbanization) would reduce marine aquatic
resources such as salmon, steelhead, and other anadromous fishes.
It would appear that your preferred alternative of a centralized
systera would conflict with Puget Sound Council of Government's King
Subregional Plan when secondary impacts are analyzed. This plan en-
courages future development within King County to utilize previously
committed land areas and existing facility systems before expanding
with new areas. One purpose of the plan is to direct growth to exist-
ing urban hubs. A centralized sewer system vrould appear to conflict
with this plan.
From your statement, it would appear that the preferred system would
also conflict with local ordinances to protect farmlands, wetlands
and other sensitive areas.
On page 95 you state: "Much of the proposed North Cre*k/Hollywood
connection will traverse agricultural land from Woodinville south to
the existing Hollywood punping station at N.E. 124th Street. ...The
alignment would require one stream crossing (Bear Creek) and construc-
tion through several wetlands just sound(sic) of Woodinville." You
also state the proposed line would traverse land within the Sammamish
Valley/Bear Creek Agricultural District and would parallel the
Sanrr.a.v.ish River Parkway.
0
Page 2
February 3, 1981
However, King County Ordinance 3064 defines agricultural lands of county
significance as: "3) Lands where urban level water or sewer lines are
not in place" Page 192.
On page 196 and 204 you state King County Sewerage General Plan excludes
sewers from designated farmlands of county significance and wetlands and
floodplains.
One purpose of King County Sensitive Areas Ordinance is to direct growth
away from wetlands, streams, steep slopes, and earthquake hazards. Again
a potential conflict exists.
We wonder if your proposal meets your agency's guidelines. Is this proposal
the least impact alternative? When considering the secondary iiriDacts does
the preferred alternative meet your wetland guidelines? Your Policy State-
ment on Protection of Nation's Wetlands reads: "In compliance with the
National Environmental Policy Act of 1969. it shall be the policy of this
agency not to grant Federal funds for the construction of municipal waste
water treatment facilities or other waste-treatment-associated appurtenances
which may interfere with the existing wetland ecosystem except where no
other alternative of lesser environmental damage is found to be feasible."
(38 FR 10834. March 20, 1973)
On page 190 you state: "EPA in 1978 established an agency-wide policy to
assure that its actions, regulations, and programs reinforce the retention
of environmentally significant agricultural land."
On page XXV you state: "EPA programs and policies require that these impacts
be mitigated where possible." However, you have decided that in this case
"neither EPA nor METRO is institutionally responsible" for the growth and
secondary impacts. Throughout the document you list mitigation measures
that are "not your responsibility" and that could be done. However, in
actuality it is highly unlikely they would ever be accomplished. For ex-
ample, you state METRO could prepare EISs for interceptors effecting farm-
lands (198), and all cities could adopt policies to protect farmlands and
wetlands (198,204).
On the other hand in discussing decentralized alternatives on page 156
you state: "In theory, acquisition of land treatment sites could support
King County open space policies... A total of 1,164 acres (alirost 2 square
miles) would be needed for land treaUnent, and this land would be assured
of long-term use as agricultural open space."
"For some of the decentralized coimiunities. construction of decentralized
facilities could lessen development pressures In interceptor sewer
corridors (page 156)."
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Page 3
February 3, 1981
?. Consultation (page 7)
In discussing the Fish and Wildlife Coordination Act, you state that
EPA procedures for implementing NEPA require consultation with Fish
and Wildlife Service and appropriate state wildlife agencies to de-
velop mitigation measures for adverse impacts. Has this consultation
tal.en place?
3. Biocheir.ical Oxygen Demand (B.0.0.) and Suspended Solids (S.S.)
Cn page 39 you state: "For the first quarter of 1980, the B.O.D. loading
was 3,700 pounds per day, and the S.S. loading was 3,200 pounds per day."
Is this an average? What was the maximum B.O.D. load in a five day period?
4. ln-Rivur Actions (page 61)
You state that alternatives of increased discharges from Howard Hanson Dam
and bank shading were considered by METRO to either be unrealistic or
ineffective as a long-term solution. However, until water quality pro-
blens in the Duwamish are ujypd. these alternatives may be necessary if
tribal, cc~ir.ercial , and sports fisheries are to be retained and restored.
5. Seismic Ha:ard
What is the earthquake potential for the alternative line crossings of the
Ouwamish? Would crossings occur in areas and soils likely to withstand
earthquake damage?
6. Impacts of Water Quality Violations (138-143)
On page 138 you conclude that, although water quality standards have been
violated, "no obvious effects on fish or biota in the lower Green/Duwamish
River directly attributable to the Renton discharge have been recorded
at effluent discharge levels to date". This statement is repeated on
page 143.
On page 141 you state: "As previously discussed, the Richmond Beach out-
fall is unlikely to create measurable adverse wjter quality impacts in
Puget Sound. Therefore, no corresponding biological impacts in Puget
Sound are expected."
Yet on page 140 you state: "High incidences of fin erosion and liver
tumors have been found in starry flounder and English sole in the
Duwjmish estuary... Fin erosion diseases have been associated with
areas of heavy wastewater discharge in the ocean off southern California.
and in the Hew York Bight.
Page 4
February 3. 1981
On page 139 you state: "However, the heavy metals in Renton effluent
would be lower than in the West Point effluent because there are fc»er
industrial sources in the Renton service area, and because the Renton
plant has a higher degree of treament." We wonder if this can expect
to continue, especially with the industrial expansion occurring in the
Green River Valley.
8. Economic Loss with Resource Loss
On page 179 you discuss the economic value of salmon. We point out
that game fish also have an economic value with a return largely to
small communities. Many small communities provide food, gear and
lodging to the angling public. The fishery is essential to the
economic survival of these small towns.
(14)
(15)
You conclude: "Therefore, one way to analyze the impacts of future
growth on fishing resources is to simply look at the increase in urban
acres within sub-drainage basins. ' (179) If a secondary impact of
your proposal would be an increase of urbanization, we wonder if your
proposal would comply with the recent Indian Treaty Fishing Right de-
cision by U. S. District Judge William H. Orrick. That decision reads:
"That is the minimal need which gives rise to an implied right to environ-
mental protection of the fish habitat. Therefore, the correlative duty
imposed upon the State (as well as the United States and third parties)
is to refrain from degrading the fish habitat to an extent that would
deprive the tribes of their moderate living needs."
(Page 31 of Civil No. 9213 - PHASE II Opinion)
9. Terrestrial Wildlife
You conclude: "Given the regional nature of the growth projections
examined in this EIS, it is not reasonable to further assess the impacts
of urbanization on terrestrial wildlife and ecosystems, largely because
these differ with different urban land uses." However, mention should be
made of two important resources that would be greatly reduced if farmland
and wetlands in the study area are converted to urban uses. Waterfowl de-
pend on these areas for food and rest as they migrate on the Pacific
flyway. Non-game species such as raptors, heron, small mammals, and song-
birds would also decline. The Green River Valley currently supports
gyrfalcon, red-tailed hawk, marsh hawk, peregrine falcon, Cooper's hawk,
and kestrel.
Important heron rookery and feeding grounds are found in Auburn. Other
species of special concern are provided in your appendix. (NOTE: We
did noi receive a copy of your appendix.)
(16)
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Page 5
February 3, 1981
Loss of vegetation near streams will eliminate wildlife migration routes,
breeding, and rearing areas for itany species.
10. State Environmental Policy Act
In discussing your sunmary of mitigation measures for sensitive areas you
state: "In addition to those already mentioned, an important mitigation
measure is the SEPA's requirement for preparation of EISs when individual
development projects could have a significant effect on the environment."
(206) While SEPA does provide for SO.T^ amount of public disclosure,
determinations of significance or non-significance are made by the public
agency initiating an action or pertntting an activity. For example, if
the City of Auburn decides that filling of wetlands and removal of farm-
lands are not significant, an environmental impact statement is not pre-
pared. Due to the fact that many public agencies have neither expertise
to evaluate significant impacts nor enough staff to prepare EISs, most
projects go through the SEPA process as Declarations of Non-Significance-
It is essential that Renton plant discharges no longer be loaded to the Duwamish.
Water quality is already violated and flatfish show signs of contamination. Pro-
posed river widening and deepening and associated development would further accele-
rate water quality problems. With a wider and deeper channel, the salt water
wedge would be increased. This, combined with additional contamination from
storrawater runoff, would take large toll on the fishery resource.
However, we reconrend an integrated wastewater program that will transfer waste-
v/ater discharges from the Duwamish to the Sound, but will incorporate decentra-
lized systems in outlying areas. Your prograrc should support rather than
challenge the protection of farmlands, wetlands, floodplains, as well as exist-
ing and potential fish and wildlife populations.
Thank you for sending your document. We hope you find our comnents helpful.
Sincerely,
THE DEPARTMENT OF GAME
Eob Zeigler, Applied Ecologist
Environmental Affairs
Habitat Management Division
BZrmjf
cc
Agencies
Region
Washington Environmental Council
National Marine Fisheries Service, Portland
Response to Department of Game Letter of February 3, 1981
1. EPA has examined the Shoreline Master Plans for King
County and the City of Seattle, which are the main shorelines
which could potentially by affected by the proposed project,
and has determined that the proposed project is consistent
with these plans. These plans encourage protection of water
quality, and such protection is afforded by diversion of
Renton effluent to Puget Sound, where it can be more effectively
diluted and dispersed, as compared to the present discharge
to the Green/Duwamish River.
King County administers the shoreline permit program
for the Seahurst Park area and would be responsible for issuing
needed shoreline development permits. The King County shoreline
management plan classifies Seahurst Park as a "conservancy"
area. Under this classification, utility uses may be allowed
subject to conditions. EPA has determined, in consultation
with King County shoreline management staff, that the proposed
tunnel outlet, pump station, and marine outfall would be
considered a utility use. EPA has therefore determined that
the proposed decision will be consistent with the state coastal
zone program. Metro will be required to obtain a shoreline
permit from King County.
Regarding secondary impacts, these have been noted in
the EIS and mitigation measures have been described, one
of which is implementation of plans such as the Shoreline
Management Plan to reduce the adverse environmental conse-
quences of urban growth.
2. A centralized sewerage system does not necessarily con-
flict with the King Subregional Plan, provided that sewers
are extended only to close-in areas. In the case of the
Metro plan, the proposed service area is based directly on
the King County Sewerage General Plan. The policies under-
lying the Sewerage General Plan, which encourage servicing
only those areas within and immediately adjacent to urban
development, are consistent with the policies of the King
Subregional Flan.
3. See General Response Number 6.
4 and 5. Should the North Creek/Hollywood Connection be
implemented, its intended function would be as a transfer
sewer, not as a collector sewer, for the lands through which
it passes, and it would thus not function to provide service
Attachment
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to agricultural lands or sensitive areas in the Sammamish
Valley. Further protection to these areas is provided by
Metro Resolution 3380, prohibiting the sewering of designated
agricultural lands and wetlands in unincorporated areas.
6. See General Response Number 6. Also, because the Redmond
and North Creek/Hollywood connections are not part of Metro's
recommended plan, potential adverse impacts on wetlands from
cons trruction of these facilities would be avoided. If the
decision is subsequently made to construct these facilities,
Metro would seek an additional construction grant, and EPA
would develop appropriate mitigation measures as grant condi-
tions for site-specific wetlands impacts.
Aside from direct impacts of the sewerage facilities
on wetlands, the EIS described secondary impacts of growth
accommodated by the wastewater plan on wetlands. These impacts
would occur regardless of which of the long-term wastewater
management alternatives is selected since each alternative
assumes a common growth forecast. Only the no-project alter-
native could partially reduce potential adverse impacts
on wetlands, but EPA does not consider this alternative to
be environmentally preferable because adverse impacts on
water quality of the Green/Duwamish River would result.
7. EPA, in accordance with NEPA regulations, has listed
mitigation measures for secondary impacts which are outside
its ability to implement, as well as mitigation measures
which could be enforced by EPA or Metro. Some of the measures
identified for agencies other than Metro or EPA may not be
politically feasible, but according to recent Council on
Environmental Quality guidance (Federal Register, March 23,
1981, p. 18028), all relevant, reasonable mitigation measures
should be included in federal EISs.
8. The intent of the commenter in citing these EIS sections
regarding decentralized systems is unclear. The Draft EIS
did point out certain land use and open -space advantages
to decentralized systems, and these advantages have been
fully considered in the Metro and EPA decision-making processes.
9. Appropriate coordination with fish and wildlife agencies
has occurred during preparation of the EIS. The U. S. Fish
and Wildlife Service was contacted by EPA early in the EIS
process regarding threatened and endangered species and other
concerns. The EIS consultant has received considerable input
from the Department of Fisheries and the Department of Game
Natural Heritage Data System. As design details and facility
alignments are resolved in the near future, Metro and these
state agencies should be in consultation for mitigation of
construction impacts.
10. On page 42 of the DEIS, the range (minimum and maximum)
of effluent BOD5 values is displayed for the period January
1979 through March 1980. The maximum daily BOD5 for that
period was 35,000 Ibs/day. Mr. Fred Holem is the Department
of Game representative on Metro's Water Quality Monitoring
Review Board and routinely receives monthly effluent quality
reports for the Renton treatment plant.
11. The RIBCO studies analyzed the temperature and DO bene-
fits associated with tree shading and low flow augmentation.
Based on the RIBCO analysis, tree shading could significantly
improve temperature and DO. However, RIBCO recommended that
low flow augmentation be implemented. Because it would be
30 years before shading from trees would be effective, RIBCO
concluded that planting shade trees was less practical and
could not be recommended without additional study. The Corps
of Engineers has stated that presently low flow augmentation
from operation of Howard Hanson Dam is only available through
coordination with Washington State Department of Fisheries
and then only to a limited extent. However, the Corps is
considering restudying dam operation to increase flow aug-
mentation capacity.
12. See General Response Number 7.
13. There is no logical inconsistency among the three state-
ments referred to. No major biological impacts on Green/
Duwamish River biota from Renton effluent have been reported
to date, and no major biological impacts of a Kenmore or
Renton discharge to Puget Sound are predicted based on existing
local data. It is true that certain biological impacts have
been reported in areas of heavy wastewater discharge in southern
California and New York, but these reports reflect local
conditions, and it would be scientifically invalid to directly
extrapolate these results to Puget Sound or the Green/Duwamish
River.
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14. It is difficult to say whether or not to what extent an
increase in heavy metals might be expected in the RTF effluent
due to further industrialization. Land use planning agencies
are unable to accurately forecast the type, location, and
amount of new industrial development. For purposes of the
Renton study, industrial flows were projected to increase
in proportion to the growth in residential/commercial flows.
Although industrial flows projected for the RTF will increase,
the total volume of industrial flow will still be less than
the volume tributary to West Point. Other factors to consider
include the effect of Metro's industrial pretreatment program
and industrial discharge permit system as well as the fact
that many heavy metals may come from residential and even
water supply sources. The toxicant studies currently underway
are designed to help answer these questions. For these reasons
Metro has concluded that heavy metals concentrations will
probably remain lower in the Renton effluent than the West
Point effluent.
15. The economic value of Green/Duwamish River steelhead
fishery was included in the total fishery value of the stream.
The other game fish species in the study area are principally
freshwater species and anadromous cutthroat; these will be
adversely affected by urbanization (Chapter 7). The economic
value of these game fish to small communities in the study
area was not estimated in the EIS because no data were avail-
able to prepare such an estimate.
16. According to the Orrick decision, potentially affected
treaty tribes bear the responsibility to prove that a state
or federal action would "proximately cause" fish habitat
to be degraded such that the tribes' "moderate living needs"
would be impaired. The only treaty tribe in the Renton study
area is the Muckleshoot Tribe. The Muckleshoot Tribe received
a copy of the Draft EIS and submitted comments. Those comments
did not raise a question about degradation of inland salmon
habitat due to urbanization. Nevertheless, EPA recognizes
its responsibility to protect fisheries resources from secondary
impacts. These impacts are discussed in the EIS. Appropriate
mitigation of potential impacts, consistent with EPA statutory
authority, is to implement recommendations from areawide water
quality management plans. These measures are discussed in
the EIS along with the local agencies responsible for imple-
mentation .
17. A statement recognizing the importance of farmlands,
wetlands, and riparian vegetation has been added to the Final
EIS.
18. The imperfections of the SEFA process are acknowledged.
Nevertheless, SEPA does require preparation of EISs for citizen
and public agency review whenever the impacts of a project
may be potentially significant. Also, citizens and agencies
have the opportunity to challenge declarations of nonsigni-
ficance if they disagree with the conclusions reached in
these documents.
19. The final plan recommended program does call for removal
of Renton effluent from the Green/Duwamish River. The rationale
for rejection of decentra? ized systems is explained in Chapter 4
of the EIS and in Metro's 'final Wastewater Management Plan.
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STATE OF WASHINGTON
'
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R.K. Modmlck/USEPA
-2-
February 23, 1981
STATE OF
WASHINGTON
John Spellman
Governor
February 23, 1981
DEPARTMENT OF FISHERIES
115 C*»rs. CVnpu. Wjda^g; IfHf r KtSKt-WX
FEB 25 1981
ENVIRONMENT.*!. EVALUATION
BSANCH
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
Draft Environmental Impact Statement
Uastewater Management Plan for the
Lake Washington/Green River Basins
METRO WRIA B-08 and 09
The Department of Fisheries has reviewed the above referenced DEIS. We have
confined our general comments on the alternatives and our specific technical
comments to those most applicable to the major design features of the Final
Alternatives (A-l, A-3, A-5 and B-l) and the subsequent impacts on species
under our jurisdiction.
General Comments
We concur with the choice of Preferred Alternative made in the DEIS. Specifically,
we support diversion of the increasing effluent from the Renton STP out of the
Green-Duwamish and into Puget Sound. Several of the specific technical comments
we have on the DEIS and appendices strengthen the arguments made in the DEIS
in favor of this diversion. Briefly, the salmon dollar values in the DEIS are
too low and the analysis has omitted some potentially very significant impacts
for Green-Duwamish salmonids. These serve to increase the potential benefit
derived from the diversion.
The alternative we find the most satisfactory based on resources under our juris-
diction is diversion of the effluent to Puget Sound at Alki Point. The alternative
which we would rank second is diversion to Point Pulley. Concerns for geoducks
at Point Pulley and the oceanographic circulation in the southern portion of
the central basin make this a less desirable alternative. The least desirable
of the "Final Alternatives" were the two which increased the Renton effluent
to the Green-Duwamish River.
Specific Comments
Salmon
The annual value of the salmon runs listed in the Appendices (p. C-91) is too
low. Tables 1-4 (attached) detail the value of the runs in the Green-Duwamish
drainage. The total annual value 1s over $4 million (rather than $2.6 million
as stated). The values calculated by the Department in the attached tables
are based on landed values (price paid to the fishermen). Use of retail
prices for the commercial portion of the catch would increase these values even
further.
The Department facilities in the drainage are valued at close to $4 million and
have an operation and maintenance budget of $347,000 for fiscal 1981. The
scarcity of good water supplies sufficient to support an operation of this size
and the harvest-managanent implications of developing alternative drainages
make replacement of these facilities in their entirety nearly impossible.
If a significant portion of the juveniles from the system or the in-migrating
adults were adversely affected by water quality problems, the fish would
probably be unreplacable. The production and returns to other hatcheries, for
example, are all preprogrammed for their drainages. Transfer of large quantities
of fish to attempt replacement of fish lost in a major fish kill, would in
effect decrease production (and subsequent returns) in other rivers. Ultimately,
fish would be lost in the fishery with corresponding economic impact.
The EIS should also discuss the implications of multiple year impacts on the
resources. The economic impact would be increased in proportion to the number
of years impacted. There is also a possibility of adversely affecting an
entire stock of fish. If impacts occurred in successive years, the entire stock
could become depressed, making recovery difficult. Effects on production and
harvest could be felt for many years if this occurred.
Uater Temperatures
In the second paragraph on page 140 of the DEIS high water temperatures are
discussed. This discussion should be expanded in several ways. The inverse
correlation between temperature and DO should be mentioned. Higher water
temperatures will reduce the oxygen-carrying capacity of the water potentially
compounding the effect on salmonids. The discussion centers around violations
of DOE temperature standards presently. Some specific numbers such as maximum
temperatures, the average of the upper 5 or 10 percent of the temperatures and/or
the increased duration of the high temperatures diurnally would place more
perspective on these violations. In addition to blocking migration, exposure
to warm water temperatures during the last few weeks of adult salmon holding
can reduce the viability of the eggs (p. 60, James Wood, Diseases of Pacific
Salmon Their Prevention and Treatment, Washington Department of Fisheries,
Second Edition, 1974).
Geoducks
The final EIS should address the potential impact on geoduck clams of the
alternative outfall at Pt. Pulley (see attached excerpts from Progress Report
No. 36). The outfall probably would entail construction in the geoduck bed and
probably result in direct mortality to the clams in the path of the construction
Recent studies have shown that geoducks are long-lived. Beds will often average
40-60 years and individual clams may live beyond 150 years. Recruitment is
sporadic and several years may pass between successful "sets" of young clans.
Recovery following construction impacts would be very slow, therefore.
3)
(4}
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R.K. Mochnick/USEPA
-3-
February 23, 1981
A second type of potential effect on clams relates to whether they can be
certified for harvest. Department of Social and Health Services (DSHS) handles
requests for certification of beds for commercial harvest. A written response
from that agency should be sought on whether the outfall would make any clams
uncertifiable which -could be certified presently. Max Hayes (753-5959) of
the Protection Unit in Olympia handles such matters for DSHS.
Due to the existence of geoduck beds around Point Pulley, we prefer the Alki
discharge location. If one of the Point Pulley alternatives is pursued, an
underwater survey might indicate a specific alignment which would minimize the
impact on the clams. From such a survey, METRO could develop an estimate of
the loss for the alignment having minimal impacts. The survey information will
be of value to the Department in making its permit decision and for determining
provisions for any permit we issue.
Oceanography
The circulation described around Vashon Island seems to recommend location of
the discharge point for the effluent north of Point Pulley. We concur with
the careful approach to this decision delineated on p. 141 of the DEIS. Good
mixing and minimum retention in the Central Basin are obviously desirable.
Potential Failure of the Treatment System
The possibility of failure of the treatment facilities should be discussed. (JO)
The discussion of possible failures should include any increased likelihood if
an advanced treatment option were pursued at the Renton plant. The probable effect
on the water quality and resources of the Green-Duwamish of an extensive failure
at the plant should also be discussed.
Specific Construction Provisions
The Department of Fisheries will be providing specific construction provisions
for the in-water work. These may include timing and allowable construction
practices. They will be developed in response to specific plans submitted
through an application for a Hydraulic Project Approval or, in marine waters,
via the Corps of Engineers Public Notice for the project.
Thank you for the opportunity to review this document. If you have any questions
concerning our response, please contact Mary Lou Mills (753-0576).
Sincerely,
Table 1 DATA AND VALUES USED IN CALCULATING THE FISHERY CONTRIBUTION AND ASSOCIATED
DOLLAR VALUES FOR THE NATURAL RUNS (TABLE 2) IN THE GREEN DUVJAIHSH DRAINAGE.
Roll and A. Schmitten,
Director
cc: Max Hayes (DSHS)
Mary Lou Mills
Species: Chinook (falls)
Catch: Escapement Ratio 2.4:1 ^
Gear
Recreational
Troll
Net
1 Caught -1
39%
44%
17%
Average Weight -
9.1 Ibs
12.9 Ibs -/
17.1 Ibs
Value
$4.26 !/
2.61 I/
1.45 V
Species: Coho
Catch: Escapement Ratio 30.5:1 i/
Gear
Recreational
Troll
Net
% Caught!/
15%
32%
53%
Average Ueight —
4.1 Ibs
5.9 Ibsi/
6.4 Ibs
Value
$2.84 3/
2.04 -/
1.88^
If Fishing rate and catch distribution for Chinook and coho are from the WDF
stock models (Richard Lincoln, WDF Pers. Comm.).
2/ Dressed weight.
3/ 1979 Value based on 1977 retail value from WDF salmon landing statistics
updated by U.S. Department of Labor, Consumer Price Index.
4/ 1979 value based on 1978 WDF Salmon landing statistics (unpublished) updated
by U.S. Department of Labor, Consumer Price Index.
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Table 3. HATCHERY DATA FOR THE 6REEW-DUHAMISH DRAINAGE -
Capital Values of WDF Facilities
Green River Hatchery -C.
Icey Creek fl (upper) -• ,.
Crisp Creek (Spaight Ponds) 5/
Icey Creek #2 (lower) 5/
Total
Annual Operation and Maintenance Costs for UDF
All facilities (fiscal 1981) except
Icey Creek *2
Icey Creek t2 (when complete)
Total
Estimated Value of the 1981 Production at all
Chinook
Co ho
Chum
Total
$3,500,000
90,000
58,000
250,000
$3,898,000
Facilities
$ 320,700
27,000
$ 347,000
Facilities
$1,928,450 |/
1,604,540 -'
45,081 U
$3,573,071
\l Personal Communication by Dean Uood, Salmon Culture, 1981.
2/ Current value including improvements since the 1940's.
3/ 1977 dollars.
4/ 1975 dollars.
5/ Under construction.
6/ Represents the value of the adults produced by 1981 plants taken
in various fisheries 2 to 4 years after planting.
TJ 1980 project marine transport harvest (3,300 fisn) multiplied tires
the 1979 value derived by updating the 1978 UDF net-caught salmon
landing statistics with the U.S. Department of Labor, Consumer Price
Indes (13.66/fish).
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Table 4.
GREEN RIVER-DUWAMISH SALMON
PRODUCTION
TOTAL VALUE (ANNUAL)
Species
Chinook
Co ho
Chum
Total
Grand Total :
Natural
$476,332
365,239
-0-
$841,571
Hatchery Prod.
$ 928,450
1,604,540
45,081
$3,578,071
Total
$2,404,782
1,969,779
45,081
$4,419,642
$4,419,642
Response to Department of Fisheries Letter of February 2 3 , _ _1L98J_
1. Though subtidal geoduck clams are found near Three Tree
Point (Point Pulley), they are also found near Alki. They
are found on both sides of Three Tree Point, but only on
the south side of Alki Point. It is possible that geoducks
near the discharge location may not be certified for commercial
harvest, as a precautionary measure (see General Response
Number 1).
2. The economic data in the Final EIS have been corrected
to reflect these revised estimates.
3. Comment acknowledged. One reason for the choice to
remove Renton effluent from the Green/Duwamish River is that
fishery losses would be irreplaceable.
4. Comment acknowledged. The effects of multiple year
impacts may be compound and result in a severe reduction
in a portion of the fish stocks. It is unlikely that the
entire stock would become depressed, since migration of
anadromous salmonids generally occurs during periods of rela-
tively high winter flow. Early running chinook adults
(September) and juvenile salmonids rearing in the estuary
in summer would be most affected.
5. Higher temperatures do reduce the oxygen-carrying capacity
of water; however, the main cause of low oxygen concentrations
in the river is ammonia from the Renton effluent. When the
effluent is removed from the river, there should be adequate
oxygen for salmonids despite temperatures that are above
the state standard.
6. An analysis of effects on subtidal geoducks has been
included in the Final EIS.
7. As noted in the Final EIS, certification for commercial
harvest may not occur near the outfall.
8. Metro will conduct detailed studies prior to design
of the outfall intended to provide this type of information.
9. See General Response Number 1.
-JO. In the evejit of a-fallure -at the Renton treatment plant,
primary—treated effluent would"-be temporarily discharged
from the outfall_io -Puget Sound. ^Metre estimates Chat this
would dec-rease plant performance from 90 percent removal
-------
of BOD and suspended solids to about 30 percent removal of
BOD and 60 percent removal of suspended solids. Failure
of the primary treatment process is considered unlikely
because of the mechanical simplicity of the process.
If nitrification were installed at the Renton plant,
as in Alternative A-l, the risk of plant upset would be
increased. If the nitrification process were to fail,
secondary effluent would be discharged to the Green/Duwamish
River, and adverse water quality and biological impacts
similar to those described for the no-project alternative
would result.
-------
IdttMSttlLMAN
Governor
DON/MOW MOOS
[Vector
STATE Of WASHINGTON
DEPARTMENT OF ECOLOGY
MjilStopPV-n . Olympa. WMhinglon 9S5O4 . IX6f753-2BOO
Mr. Roger K. Mochnick
March 11, 1981
Page Two
"MR 16 1931
March 11, 1981
Mr. Roger K. Mochnick ENVIRON-' '•' »!_ [VALUATION
Environmental Evaluation Branch BiMituH
U.S. Environmental Protection Agency
1200 Sixth Avenue - Mail Stop 433
Seattle, Washington 98101
Dear Mr. Mochnick:
Thank you for the opportunity to review the draft Environmental Impact
Statement (EIS) on the Wastewater Management Plan for the Lake Washington/
Green River basins. Although your request for review and comment referred
specifically to this EIS, I think it is also important to comment on the
overal1 situation.
The Department of Ecology (DOE) is concerned
and nonpoint pollutant sources in Puget Soun
We understand that METRO has considered the
about the Impact of all point
d and the Green/Duwamish River.
We are hopeful that the METRO planning process can rapidly be brought to a
close so that they can develop needed financial planning and implementation
proposals. The decision-making process Is complicated by METRO'S appli-
cations for marine waivers which are currently under review, but con-
tinuing Inflation and threats to "water quality are significant motivation
to seek a solution rapidly^
We agree that only alternatives A-3 and A-5 could folly eliminate water
quality .concerns in the Green/Duwamish River which are presently caused or
aggravated ty the Renton discharge. Therefore, alternatives A-3 and A-5
are the only acceptable alternatives. We recognize ttie following advan-
tages and disadvantages of the two general discharge locations:
Water Quality - There may be some qualitative wa-t-er quality bene-
fit to the Alki Point discharge. This is due to the predomi-
nantly northward flow of the marine currents 4n this area.
The Point Pulley area has southward flow which may result In
a discharge having a longer residence time in Puget Sound.
Both discharge locations are acceptable since they offer
immediate dilution of 100 to 1 within one mile of the
diffuser and 500 to 1 in one tidal cycle.
Dollars - The Alkl Point discharge location is between $80
to $110 million more expensive for capital cost and $60
to $88 million more expensive on a present worth basis
than tlie acceptable Point Pulley discharge locations.
This money could be used to solve more urgent water quality
problems. There is some potential for future cost savings
at the Alkl location should the Alki treatment facility be
abandoned and/or the Duwamish plant be constructed. These
savings would not eliminate the cost advantage of Point
Pulley.
Land Availability, Construction Impacts - There are significant
problems in obtaining the right of way for the outfall along
the Duwamish River, as well as significant traffic and busi-
ness disruption during construction which would not be as
severe with the Point Pulley discharge locations.
METRO should evaluate these factors and others in selecting the final dis-
charge location. Additional water quality benefits should be shown along
with other advantages to justify the much greater cost of an Alki Point
discharge location.
Detailed comments on the EIS are enclosed. Please contact Norm Glenn of
my staff at 753-2846 if you have any questions.
Since
Director
DWM:hf
Enclosure
-------
The comments below refer to specific pages in the draft EIS:
Page 27 - The value of the fishery resource is substantially undervalued
From a review of the catch records of the Department of Game, May 1
1979 through April 30, 1980, we would anticipate that the economic
value in current dollars of the fish harvest to the area may be two
to three times the figures stated. These figures do not appear to
take into account the cost of replacing the resource. Our figures
indicate that the loss in terms of resource replacement and lost
revenue from the catch for a single year for steelhead along would
exceed $10,000,000 based on 1979 fish values and catch records.
Pa_ge_4j - Heavy metals concentrations for copper, chromium and zinc are
at the threshold limits for affecting organisms in fresh water or
above. Proposals to handle sludge at Renton and the interception
of leachate from Cedar Hills to Renton STP will likely increase the
levels of all the heavy metals in the effluent. This further
supports the need to cease the discharge to the Green/Duwamish River.
Page 48 - The mound system is the same as a septic system, only the soil
application method differs.
Page 59 - Control of BOD and solids is not within the scope of the METRO
toxicant study.
Page 66 -
tha
be considered equal economically .
Page 87 - It should be clarified that METRO does not have jurisdiction
presently in the area of design, construction, operation and main-
tenance of onsite disposal systems.
Page 120 - Relatively high concentrations of heavy metals are found near
the Alki Point and West Point STP ourfalls. A similar situation
may be expected surrounding the Renton STP outfall if it was
diverted to Puget Sound although the risk of this is minimized be-
cause of the secondary treatment proposed at Renton.
Page 122 - The outfall to Puget Sound is a very key element of the pro-
posed alternative . Impacts for the proposed outfall alternatives
are adequately addressed for decision-making purposes. When the
preferred location is selected, additional more detailed analyses
of the impacts should be performed .
Page 124 - 125 - Loading levels of ammonia, nitrate and phosphate
expected to be discharged into Puget Sound should be Identified.
The impacts of these nutrients on the water quality and biology
in Puget Sound surrounding the outfall point should also be dis-
cussed .
127 - A standby emergency power source should
Totem Lake pumping station in order to prevent
be provided at the
bypassing of raw
sewage into the Sammamish River. A bypass at the Redmond con-
nection pump station at Totem Lake would not be permitted unless
it is necessary to protect life or property. This subject should
be furtehr clarified.
143 - Alternative No. 4 (primary treatment to excess flows) is not
acceptable because water quality violations would occur and fish
kills would be a possibility.
|®
- 67 - Cost estimates for alternatives A-l and A-3 are so close \/^\
t their costs are within estimating errors and could, therefore Jv*/
8)
-------
Response to DOE Letter of March 11, 1981
1. See General Response Number 2.
2. See General Response Number 1.
3. See General Response Number 9.
4. 'Metro has evaluated the factors noted by DOE and other
factors, and has recommended a Seahurst Park discharge in
its final plan. EPA has also evaluated relevant factors
and also has identified Seahurst Park as a preferred outfall
location. The rationale for Metro's selection of Seahurst
Park is summarized in Chapter 2 of the E1S and described
in greater detail in Metro's Final Wastewater Management
Plan. The rationale for EPA's decision is discussed in
the Foreword to this EIS and in Chapter 8.
5. The economic value of Green/Duwajnish fish stocks has
been revised in the Final EIS. The total annual value exceeds
$10 million.
6. This correction has been made in the Final EIS.
7. See General Response Number 11. Metro has performed
an inflation analysis which shows that at inflation rates
exceeding 3 percent, Alternative A-l becomes more expensive
than A-3 in present worth terms.
8. This correction has been made in the Final EIS.
9. The impact of heavy metals accumulations in sediments
near the Renton outfall is described in the Final EIS.
10. Additional oceanographic and biological studies of the
outfall are planned by Metro.
11. The Final EIS includes estimates of effluent quantity
and quality, from which loadings can be calculated. The
effects on water quality, algae, invertebrates, and fishes
are also analyzed in the Final EIS.
12. Metro reports that such a standby power source would
be in place.
-------
REGIONAL AND LOCAL AGENCIES
345
-------
Seattle. WA 98104 • 206/464-7090
Puget Sound Council of Governments
January 8, 1981
Roger K. Mochnlck, M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear- Mr. Mochnick,
r.ECEfVED
''IN 0 RED
The King Subregional Council has reviewed the development of the
Draft Renton Facilities Plan (Wastewater Management Plan for the
Lake Washington/Green River BAsins) and the earlier Facilities
Plan for the Puget Sound Plants. We appreciate this opportunity
to review the Draft Facilities Plan and the Environmental Impact
Statement, and submit the following general remarks and attached
specific comments on the EIS document.
Our principle concerns are (a) the need now to look at both fac-
ilities plans as a single proposal within the context of declining
revenues, (b) uncertainty over the level of treatment and discharge
requirements for Puget Sound and the Duwamish River, and (c) the
institutional prerequisites for the proposed "triggering mechanism"
governing long term decision-making.
General Comments
A. Systemwide Alternatives
Metro facilities planning includes proposed plant abandonments
(Alki, Carkeek Park) and rerouting of wastewater into the Renton
service area for treatment, resulting in the concentration of
King County wastes on the Duwamish River. The assimilation
capacity of the River is severely limited during the summer
months. (Summer flows at Auburn drop to 300 cfs during normal
years, but the average annual flow is much greater at 1,360
cfs.) The Draft Plan suggests that the remaining choice is
between two discharge tunnels connecting the Renton treatment
plant to Puget Sound (at a cost of 128 million dollars or 198
million dollars, EIS, p. 72).
However, using the "building block'1 approach employed in each
of the two facilities plans (Renton and the Puget Sound Plants)
it might be possible to develop systerowide alternatives which
avoid this cost and which are less costly overall than the
identified "least cost" alternative.
As Metro enters this phase of its planning, we ask that you
evaluate our illustration (specific comments, page 63) which
considers the continued use and partial upgrading of the exist-
ing plants as the least cost systerawide alternative, and com-
(D
Roger K. Mochnick
January 8, 1981
Page Two
pares this to the combined Renton Facilities Plan preferred
alternative and the Duwamish Configuration.
B. Receiving Waters
The Draft Plan assumes that "either higher levels of treat-
ment will be required (for a Duwamish discharge) , or else
the treated wastewater will have to be diverted to Puget
Sound" (Page 9). An alternative to either higher treatment
or the tunnel options might be to "divert" only those future
discharge volumes which exceed the present 36 mgd discharge.
Based on the EIS (pp. 138 and 143) it is unclear whether the
present discharge is significantly detrimental to the Duwamish
and how its removal would actually affect the Duwamish water
quality (specific comments, pages 129, 141).
We suggest for consideration the continued use of the present
36 mgd Duwamish discharge, combined with delineation of a
future Renton service area smaller than that assumed in the
Draft Plan, and the use of a holding basin to receive the
excess treated wastewater during the summer months. The
holding basin could be a multiple use facility used for
wintertime flood water retention. Such a facility located
near the Renton treatment plant (also near the Black River
pump station) is a key element in the flood control plan
preferred by the Basin Executive Committee composed of
the local governments in the valley. Costs could be shared.
This scheme would probably require the upgrading and con-
tinued use of the Alki and Carkeek Park treatment plants
so that the West Point plant could continue to accommodate
its present service area. The long term need for a Kenaore
plant would depend in part on service decisions for south
Snohomish County and site related decisions for the Metro
service area.
C. Triggering Mechanism
For the long term, the Draft Plan clearly removes land use
decisions from the Metro Council, and proposes modular sys-
tem expansions triggered by the collection and interpretation
of water quality data. However, adoption of this approach
by the Metro Council for the long term portion of the Plan
will not assure the active participation of the referenced
agencies and jurisdictions to accomplish the following:
C3)
-------
K. Mochnick
January 8. 19-81
Page Three
. Taking part in and jointly chairing the planning sessions
triggered by the Metro data (EIS, p. 105),
. Monitoring of septic tank/groundwater interactions (EIS,
pp. 187-8),
. Metro aid to local agencies in comparing on-site waste
.management proposals with conventional methods (particularly
comparing total costs and benefits, and ensuring that the
selected on-site methods for the "uncertain" sewer areas
are compatible with possible future sewer construction),
. Routine preparation by PSCOG of sub-basin forecasts (EIS,
p. 109) and the implied willingness of EPA to accept a
range of forecasts reflecting uncertainties on such fac-
tors as national* economic trends, political considerations,
major investment proposals (Interstate 90) and funding for
wastewater facilities themselves,
. A willingness by local communities and unincorporated areas
to accept their "shares" of future residents,
. A coherent set of criteria for allocating federal, state and
Metro revenues between the two facilities planning areas
(Puget Sound Plants, and Renton service area) and for deal-
ing with both point and non-point sources of pollution.
We note that local inaction in dealing with water quality issues
identified through the triggering mechanism or other means can
result in administrative directives from the State Department of
Ecology which are exempt from the Resolution 2933 process.
In raising these institutional questions we recognize that short
term decisions are not affected, and we recognize the limited
authority of Metro to impose the necessary commitments. We
believe that the Draft Plan and EIS will be useful in dealing
in a collaborative way with the complex issues of pollution,
growth management and limited revenues. We commend Metro, EPA
and the consultant teams for preparing these very concise and
readable documents.
Sincerely,
Councilmember Doris Cooper, Chairman
King Subregional Council
Enclosure
U, 168
SPECIFIC COMMENTS
WASTEWATER MANAGEMEMENT PLAN
for the
LAKE WASHINGTON/GREEN RIVER BASINS
Comment
While EPA and Metro are not ''responsible" for growth
it is clear that the pattern of development is largely
an economic phenomenon influenced by grants for capital
construction. The lack of such grants for new areas
would also have an impact on presently served areas.
This factor is corrected by the Clean Water Act of
1977 which provides funds for both centralized waste
treatment systems and on-site systems and by resolution (g\
2933 (Metro) which requires local jurisdiction cer- ^
tification of proposed capital construction.
(One possible objection to Resolution 2933 is that
it also gives local jurisdictions an effective veto
over privately funded connections to the Metro system.)
Metro's planning effort for its Puget Sound plants
has influenced the present study by recommending de-
emphasis of the West Point plant, thereby increasing
the Renton service area. Metro Resolution 3163
authorizes this diversion "to the Renton treatment
plant or another plant for treatment as part of the
Renton 201 facility planning work." Policy positions
for actual implementation have not been taken.
The Solid Waste Management Board for the King County
area is the King Subregional Council of the Puget
Sound Council of Governments.
The Air Quality discussion is incomplete. For example
Bellevue CBD is only one of four CO hotspots in King
County (others are Seattle CBD, Northgate, and the
University District). The question is whether the
level and distribution of growth affects pollutant
concentrations in a significant and consistent manner.
Two extremes to be avoided are excessive sprawl which
would aggravate hydrocarbon emissions, and excessive
infilling (i.e., due to a mismatch between infilling
policies and actual infilling capacity relative to
forecast growth) which would aggravate CO concentrations.
In both cases, however, the major factor affecting future
emissions and concentrations is the Federal Motor
Vehicle Control Program.
-------
Specific Comments
Page Two
Specific Comments
Page Three
Page
22
38
40
49
62
63
63
Comment
All of the maps should be oriented in the conventional
manner with the north arrow pointing up.
It should be possible to indicate the actual chlorine
contact time for high and low flows, comparing this
to the required standard.
The wastewater flows for the summer months on Figure
2-10 do not agree with the numerical values given on
page 41 (Table 2-7). Table 2-7 shows that during the
periods of low Duwamish flows (the summer months), the
design capacity of the plant have not been exceeded.
This fact would appear to be more significant than the
annual average flow (38.4 mgd) which does exceed the
36 mgd design capacity.
If average wet weather flow .s roughly proportional
to population level, then the draft PSCOG population
forecast corrections (September 10, 1980, and Don
Pethick meno November 7, 1980) would increase the
101 mgd figure to 107.6 mgd. (The qountywide population
for the year 2000 rises from the previous figure of
1,575,300 to 1,678,800.)
Document the DOE "Lake Washington policy" and the
"nondegradation policy", including copies in the
appendix. Was the former adopted largely for fiscal
reasons at a time when secondary treatment was not
required for discharge into Puget Sound from areas
of new growth (any waivers will apply only to existing
discharges.).
It is our understanding that the screening.of alternati
includes a fourth step: a double-check of the final pro
posal to see if any major decisions would be altered
by higher population assumptions. Other assumptions
will also come under periodic reviews through the pro-
posed triggering mechanism which serves to evaluate
both expansion timing and basic assumptions on which
the plan itself is based (see the Draft Plan, p. 100).
Uniting the Renton Facilities Plan with the previous
Puget Sound Treatment Plants Plan (1977) , a different
"least cost alternative" is apparent. This consists
of secondary treatment at all existing plants except
West Point for which a waiver has been requested.
63 (confd)
©
66
72
Comment
From the Regional Draft EIS (1977) Alternative E
would cost 369.7 million dollars(Table 3-26). Sub-
tracting the cost of West Point secondary, and
converting to a Construction Cost Index of 3500,
we arrive at a systemwide cost of 342 million dollars.
(With the West Point Plant upgraded to secondary,
the total cost is 497.7 million dollars.)
The "least cost" alternative proposed in the present
EIS would be joined to the assumed Duwamish configura-
tion for the Puget Sound plants. The Duwamish scheme
has a capital cost of 374 million (The Preferred
Facilities Plan, August 17, 1978, Table 1). Subtracting
the assumed Renton costs (121.4 million) and converting
the new total to a Construction Cost Index of 3500,
we arrive at a Duwamish cost (less Renton) of
294.7 million dollars.
To this can be added the cost of the different
Renton Facilities Plan alternatives. Using alternative
A-5 (with the Alki outfall) we would add 300 million
dollars (357 million less 57 million for tunnel and
outfall costs covered by the Duwamish proposal) .
The total cost of the "least cost" alternative under
a systemwide Duwamish plus Renton configuration is
595 million dollars.
Adding Alternative A-l to the Duwamish proposal would
give a lesser total of 562 million, but this still ex-
ceeds the 342 million dollar alternative noted above.
The above analysis is illustrative of how the "building
block" approach suggested in the 1977 Facilities Plan
discussions might be applied in developing a systetrwide
package, within future funding constraints.
Indicate the energy commitment of the different al-
ternatives as a percent increase over present levels. N
For example, the 98 million Kwh represents a 250% (17j
increase at the Renton plant and a 1327. increase
systemwide (base year figures for 1975 are given in
The Draft Regional EIS, 1977 p. 401).
Alternatives A-3 and A-5 may remove effluent from
the Duwamish, but this might aggravate the temperatu7e
problem as a net impact. If the high temperature is
due to low flows rather than effluent (RIBCO, Part III ,
p. 185) the Duwamish discharge may be a benefit to the e
-------
Specific Conmeitts
Page Four
Specific Conments
Page Five
78, 79
87
122
125
Comments
Ccont'd) tent that it aids flushing. This might
override any effects of the marginal temperature
difference between the Duwamish and the effluent.
In future fiscal analyses Metro should consider
delays and inflation as a possible "overriding
factor" in alternative selection. What are the
relative merits of each scheme with respect to
potential lawsuits, administrative delays (etc.).
The very low inflation of 0 and M costs assumed
in the Plan should also be varied (a "sensitivity
analysis"). What effect might a waiver request
denial have now, or at the five year renewal period?
In hearings before the Congressional Committee on
Public Works and Transportation some participants
reported that even for moderately sized projects
(10 to 15 million dollars) they are avoiding the
75 percent federal grants because the grant does
not cover the additional delay costs (Hearings,
96th Congress, October 30, 31 and November 1, 1979).
Near term actions should not determine the long
range alternative selection. Inclusion of the
Renton Tunnel as a near term action is probably
proposed here due to construction time needs and
the rapidly increasing Construction Cost Index
(historically rises twice as fast as inflation).
The necessity of the tunnel should not be assumed,
although the necessity for a clear and resolute
decision on future Metro actions is imperative.
While Metro cannot generalize about specific sites,
a commitment could be made in the Facilities Plan
to help local agencies compare the total costs of
onsite systems to centralized systems. The com-
parison would match the costs of interceptors,
collector systems and treatment capacity (and
discharge) to the costs of onsite systems and
graywater facilities. Grants are available for
both approaches.
The DOE minimum streamflow regulations are guidelines \,~.
for reviewing future diversion requests; they are
not instreatn flow guarantees against present diversion!
rights or the vicissitudes of weather.
The cost of removing the highly toxic chlorine residual
is apparently very minor (see Table 3-7). Can any in-
formation be provided on the danger of chlorine reacting
129
141
Comments
(cont'd) with wastewater to produce volatile chloroform
which can then enter the atmosphere and react to
destroy ozone (RAIN Journal of Appropriate Tech-
nology, April 1976). If this is the case, prohibition*
against aerosol propellants would yield insignificant
results in preserving the ozone layer.
The question is whether the current mixing ratio
of 4:1 is acceptable or not (DOE standard of 20:1
is a recommendation, page 143). Comments on pages
138 and 143indicate that no harm is resulting from
the present discharge.
If the 4:1 ratio is acceptable, then the problem
facing Metro is not so much one of removing Renton
discharges from the Duwamish, but of ensuring that
present discharges are not increased. This is par-
ticularly true if the causes of temperature and
dissolved oxygen violations do not include the
Renton discharge (RIBCO, Part III, p. 185).
Consider the following scenario. The year 2000
flow can be reduced to 74 mgd if 27 mgd is retained
in the West Point service area. Of the remaining
74 mgd only 61 mdg need be considered during the
critical summer months (the 101 mgd flow used in
the Plan and EIS is the Average Wet Weather Flow,
while the Average Dry Weather Flow is applicable
in the summer months; and a ratio of 5/6 for
ADWF/AWWF can be derived from data on page 109) .
Subtracting 36 mgd (present discharge to Duwamish)
from the 61 mgd (year 2000 discharge) gives a total
of 25 mgd which might be disposed of in some manner
other than the proposed tunnel outfall.
A holding basin doubling as a wet weather drainage
detention basin under the Green River Basin Executive
Committee Preferred Alternative (to be located near
the Renton Treatment Plant) could be used. A pond
with a four month capacity and 15 feet deep (typical
lagoon depth) would require 500 acres, the cost of
which could be shared vith the flood control project.
The description of the "impacts of no-project"
appear to overstate the DO issue, judging from the
information provided on page 135 (in 2000 the number
of violation days increases from 77 due to natural
or other causes unrelated to the outfalltto 89)
24)
2S)
-------
Specific Comments
Page Six
Specific Comments
Page Seven
Comments
Comments
150
153
160
(cont'd). Moreover, it is unclear whether the
possibly beneficial flushing effects of present
and future discharges on temperature have been
considered in evaluating the DO problem (DO is
diminished as temperature rises, and flushing
would tend to moderate solar heating during the
periods of natural low flow ).
The PSCOG does not reject the use of 2030 forecasts.
These might be compared to unofficial 100 year
forecasts prepared jointly by the PSCOG and local
jurisdictions (Seattle, King County, Bellevue) in
connection with the Seattle Comprehensive Water
Plan, and noted elsewhere in the EIS.
The important issue to PSCOG is that long term
forecasts be used only for the specific purpose
for which they were developed, and that near term
actions based in part on such projections not be
self-fulfilling. An outfall location determined
by the assimilation capacity of the selected re-
ceiving waters, and separated from the land to
be provided service by a modular treatment con-
figuration, addresses these concerns.
Since the purpose of the Clean Water Act is to
provide "swimmable and fishable" waters, these
benefits--the purpose of the proposed action--
can be noted in the discussion of recreational
opportunities.
The PSCOG regional growth projections do in fact
test the consequences of providing and constraining
sewerage collection systems. These are the "trends'
the "policy" numbers, respectively. This issue is
handled better in other parts of the EIS.
Future work by land use agencies should address
the adequacy of the King County Sewerage General
Plan service area (infilling) to accommodate new
growth forecasts. One forum for doing this is
the General Development Guide of the County, and
one piece of useful information will be the Urban
Infill study for the King County area being done
by Real Estate Research Corporation.
165
169
170
172
179
183
The observation that any forecast diminishes in
reliability as its time horizon increases, is
appreciated. This applies to the Bureau of Economic
Analysis forecasts endorsed (and required) by EPA
for use in its funding programs. To the extent that /VT\
funding decisions are influenced by the BEA forecasts '•**/
EPA is influencing the economics of land use and
the distribution of growth. This is not necessarily
bad, but it does highlight the complexity of the
land use questions (see comment for p. xxv, and 159).
Draft population forecasts for King County under
review by PSCOG (Don Pethick, November 7, 1980)
can be added to Table 6-3:
1980: 1,256,800
1990: 1,442,900
2000: 1,678,800
Changes in population forecasts do not necessarily
require a re-evaluation of consistency between the
Metro program and air quality programs. Air quality
forecasts are imprecise. Altered population fore-
casts which are within the margin of error should not
require major plan reviews.
The significant factor is not pollutant loading rates,
but rather the actual removal rates during storm events.
Additional high growth drainage basins are indicated
in King County's "King County Streams: A Disappearing
Resource" Subbasins which are over 10 percent urban-
ized and which will experience at least a 50 percent
growth in impervious surfaces are: Lake Sammamish,
Juanity Creek, Black River, Mercer/Kelsey Creek, and
Lower Puget Sound (in addition to those already listed)
34
35
It would be more accurate to say that PSCOG assumed
a year 2000 unsewered population (as a basis for model
rather than that we projected the 124,078 unsewered
population as a result of our modeling. The real
figure will turn on relative costs, the King County
program, etc. A leading planning question for Metro
is the sensitivity of Metro proposals to variations
in assumed ratios of sewered to unsewered population
(e.g., as these variations affect the rate base and
forecasted monthly service charges).
ing)
-------
Response to PSCOG Letter of January 8, 1981
1. Metro's recommended program has incorporated this system-
wide cost-effectiveness approach.
2. See General Response Number 3.
3. Such a holding pond scheme in a joint project with the
proposed P-l project was analyzed. A reservoir of some 500
acres (approximately the size of Lake Union) would be required
to store effluent during the summer, low river flow period.
The reservoir would essentially be treated as an aerated
lagoon. The recreation aspects of the P-l project would
probably be compromised. Migrating salmon traveling upstream
through the P-l pump station fish passage structure would
probably be eliminated. The cost of 500 acres of contiguous
land and additional buffer area would be extremely high.
The availability of such acreage is very questionable. The
reliability and level of protection offered the river would
be much less than diversion to Puget Sound. For these reasons,
the summer storage option was dropped from further consideration.
4. The triggering mechanism is described in more detail
in Chapter 4 of Metro's Final Plan. Parameters to be monitored
include population, wastewater flows, and sewer service areas.
In the event that monitoring indicates the need for some
type of structural or nonstructural response, Metro proposes
to notify local land use agencies of monitoring information
to encourage their early involvement in decisions on needed
response. Metro proposes to consult with these land use
agencies for guidance as to the best land use planning
scenario(s) to be used in facilities planning. In the non-
sewer area, land use agencies would have the lead in identifying
potential problems and determining needed responses.
5. The EIS, in Chapter 7 (Secondary Impacts), recognizes
that wastewater facilities do play an important role in the
urban development process. Nevertheless, the approach taken
in the EIS is that regional wastewater facilities, such as
those proposed by Metro, assist in accommodating the growth
planned for and projected by general purpose governments.
6. The final Metro Facilities Plan's recommended program
incorporates a rethinking of the West Point de-emphasis strategy.
A decision on that strategy has been deferred until after
planning for Metro's Puget Sound treatment plants has been
finalized.
7.
Table 1-1 has been corrected to reflect this comment.
8. The EIS is concerned only with those CO hotspots within
the Renton study orc-.i, and Hrlli-vue is tin- only such hotspot.
9. The relationship between urban growth and air quality
impacts is quite complex, as the comment correctly notes.
Nevertheless, the approach of the Clean Air Act toward deter-
mining project consistency with State Implementation Plans
(SIPs) relies on determining the consistency of the growth
projections underlying the project and the SIP, and this
approach is therefore the appropriate one to be employed
for the EIS.
10. The maps are intended to be read by turning the document
90 degrees, so that north is on the reader's left.
11. Current disinfection practice at the Renton treatment
plant is to dose effluent with chlorine gas and maintain
a contact time of about 1 hour in the chlorine channel.
Before discharge to the river, the effluent is dechlorinated
with sulfur dioxide to reduce the chlorine residual to
chloride ion and prevent toxic effects on aquatic life upon
discharge.
12. The tabulated historical flows are considered to be
more accurate than the graphed flows. However, updated his-
torical flows for the summer of 1980, as shown on Figure 1-5
of the Final EIS, show that the design capacity of the plant
has now been exceeded even during the low flow summer months.
13. The updated population forecast would result in slightly
higher wastewater flows. However, Metro staff believes the
difference is not significant enough to require provision
of increased capacity for the year 2000 at the Renton plant.
If the revised forecast were to be realized, the year 2000
capacity provided at the Renton plant would be used up slightly
sooner than the year 2000, and planning for additional expan-
sion would be undertaken slightly sooner.
14. These policies are documented in Chapter 6 of Metro's
Companion Document to the Wastewater Management Plan. DOE
has stated that discharges to Lake Washington, even with
secondary treatment, would not be acceptable. This is pre-
sumably based on water quality rather than cost considerations.
15. This statement is correct and no response is required.
16. See General Response Number 6 above.
17. Current energy use of the Renton plant has been added
as a footnote to Table 6-9 of the Final EIS, for comparative
purposes.
18. See General Response Number 3. High temperatures are
mainly a result of lack of riparian vegetation(shading).
Since the effluent is usually wariter than the river, the
-------
effluent does have an adverse effect on temperature. The
effects of effluent flow per se on temperature would not
be significant in the short reach of river between the
plant outfall and the estuary.
19. The impact of inflation and its impact on the ranking
of alternatives was considered in Metro's Draft Plan. At
inflation rates greater than 3 percent Alternative A-l has
a greatei present worth than Alternative A-3. The financial
planning section of the Final Plan (draft, pages 78-83) dis-
plays the impact of inflation on monthly sewer rates.
As explained on page 50 of the Draft Final Plan, the
accuracy of cost estimates and probability of lawsuits and
administrative delays is considered to be equal for all alter-
natives and thus not an overriding consideration. Thus,
we did consider these factors but determined that they did
not alter the selection of a preferred alternative.
20. The notion of near-term projects was developed for the
Preliminary Plan. At that time Metro staff had not completed
its evaluation of the alternative long-term wastewater manage-
ment programs and had not identified a recommended or pre-
ferred program for the Renton system. So as not to bias
the evaluation and selection of a preferred long-term program,
all near-term projects had to be consistent with all of the
long-term wastewater programs being considered. The tunnel
to Puget Sound was not identified in the Preliminary Plan
as a near-term action because it was not a common element
of all the alternative long-term programs. Because the recom-
mended long-term program described in the Draft Plan called
for diversion of Renton treatment plant effluent to Puget
Sound, the tunnel became a near-terra action consistent with
the long-term program. In the Final Plan the recommended
long-term program (Chapter 3) is discussed in a chapter
separate from the near-term collection system projects
(Chapter 5). The tunnel is a key element of the long-term
program. The near-term collection system projects are all
fully consistent with the recommended long-term program.
21. Pages 98 and 99 of the Draft Plan explain how the costs
of sewers and on-site systems can be compared. The Renton
facility plan is a regional wastewater plan that was not
intended to address site-specific, community scale nonstwer
or sewer issues.
Sewer vs. septic tank issues must be addressed on a
case-by-case basis at the local community level. One of
the primary functions of the triggering mechanism (Chapter 4,
Draft Final Plan) is to initiate such analyses in nonsewer
areas.
Metro's present Facilities Plan is not a plan for seeking
federal or state funding for on-site system recommendations.
Both federal and state funding programs have specific set-
asides to ensure funding opportunities for innovative and
alternative wastewater projects. Therefore, there should
be minimal effects of the present Facilities Plan on future
funding for implementing nonsewer recommendations. Since
EPA will not be asked for funding of nonsewer projects as
a result of Metro's Facilities Plan, this EIS does net evalu-
ate costs and impacts of the detailed nonsewer recommendations.
22. A correction has been made to the Final ETS text to
reflect this fact.
23. There is no specific information on this occurrence
in the Renton system. Dechlorination may not be used because
there may be sufficient chlorine decay in the effluent pipe
due to the long detention time. In any case, dechlorination
would not destroy the chlorinated organic compounds formed
during the chlorination process. If this is a problem, then
the answer would probably lie not in dechlorination, but
in an alternative disinfection process.
24. See General Response Number 3. A 4:1 ratio is not
acceptable. The DOE would like a 20:1 ratio. A 4:1 ratio
results in metals concentrations above EPA standards. Rece'nt
studies indicate the Renton discharge is a causative factor
in temperature and dissolved oxygen violations. Present
flows of 36 MGD to the Duwamish are not acceptable.
25. See General Response Number 3 above.
26. See General Response Number 3. The number of violation
days refers to temperature, not dissolved oxygen. The Final
EIS considered the possible beneficial flushing effects of
the discharge, and found that the discharge has a net detri-
mental impact on the estuary. The flow effects of the dis-
charge would not lower the river temperature except when
the temperature of the effluent is lower than river tempera-
tures.
27. The Seattle comprehensive plan population forecasts
in their current form cannot be disaggregated for the sewer
service area and Renton study area. If PSCOG is able to
reaggregate the Seattle comprehensive plan projections into
a comparable form, the forecasts might be useful in planning
(sizing and staging) nonmodular facilities.
28
This concept has been added to.the Final EIS text.
-------
29. Although the policy forecast does constrain sewerage
availability, it is not truly a no-project forecast. Such
a forecast would assume a lack of further expansion of
regional treatment plant capacity at the Renton plant, which
is a far greater constraint than merely limiting the avail-
ability of sewerage facilities to close-in portions of the
study area.
30. No response required.
31. No response required.
32. These forecasts have been added to Chapter 7 of the
Final EIS.
33. This comment is correct. Minor changes in population
and emissions forecasts would not require a re-evaluation
of the Metro program for consistency with the SIP.
*
34. Pollutant loading rates have been used as a rough index
of nonpoint source pollution potential in the EIS. A more
refined analysis would consider removal rates, as noted by
the comment, but such a refined analysis is beyond the scope
or needs of the EIS.
35. The additional high-growth drainage basins have been
noted in an addition to Chapter 1 of the Final EIS.
36. This correction has been made to Chapter 7 of the Final
EIS.
-------
(PSO
Grand Omril on the Park . 216 First Avc
South . Seattle. WA 9810-1 • 206/4&4-7090
Puget Sound Council of Governments
GrinO ComU o« It* fuk .7l6finl Av«nuc SouTh . S«itllf.WA 9BIO< • 206M64
February 5, 1981
Roger K. Mochnick, M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick,
9 1981
wi.e
On January 8, 1981, the King Subregional Council submitted to
you its comments on the Draft Renton Facilities Plan and Draft
EIS. One suggestion raised in the review was the use of a holding
pond to receive treated Renton STP wastewater during the low flow
period of the Duwamish River.
We are submitting a variation of this proposal which would pro-
vide additional treatment to the increase in Renton loads, but
not to the total Renton load. ThTscould avoid what might be
an insurmountable land assembly problem.
We are asking that the attached material, together with the original
proposal, be treated as an alternative within the final EIS. The
major feature of this alternative is that it avoids the high costs
of the discharge tunnel under A, and A,, and also avoids the costs
of totally upgrading the Renton plant \A-,) . In both of our sug-
gestions, the total flow handled by the Renton plant in 2000 is
reduced by routing the northern part of the proposed service area
to West Point (and possibly a later Kenmore plant).
The pivotal issues in this alternative are the actual condition
of the Duwamish River under present Renton loadings, the relative
importance of the Renton discharge compared to other point, non-
point and natural causes of pollution, and the net effect of re-
moving the total Renton discharge. On behalf of the King Sub-
regional Council, we are asking that these questions be addressed
in the final EIS.
(D
Puget Sound Council of Governments
MEMORANDUM January 29, 1981
TO: Water Resources Committee
FROM: Pete Beaulteu
SUBJECT: Renton Facilities Plan Alternatives
In the January 8, 1981 letter to EPA regarding the Draft Renton '
Facilities Plan and EIS, the King Subregional Council recommended <
that the "building block" technique be used to develop additional ,
systemwide alternatives. One illustration, involving joint use '
of a Renton area holding basin for treated wastewater--an alter-
native to the proposed Renton tunnels--was explored.
Because of the land requirements--500 acres--a second more real-
istic configuration is sketched below. Both alternatives assume
a continued 36 mgd discharge of secondary treated waste into the
Duwamish, with the new facilities handling any additional flows,
which are diminished by a further assumption that flows from i
north King County (27 mgd in 2000) will not be routed to Che j
Renton plant. |
The new alternative would provide "advanced" treatment for any
flows above the current discharge(The term "advanced" is some-
what of a misnomer since nitrification was a common treatment
step prior to the 1930's.) While extra treatment is apparently
required only during the summer time low flows in the Duwamish,
the process would be utilized continuously to avoid the operational
problems of switching the facility "on" and "off". This alternative
differs from Alternative A, only in the amount of wastewater
treated at this higher level (37.5 mgd rather than 101 mgd, in
the year 2000). It differs from Alternatives A3 and Ac in the
elimination of the costly tunnel to Puget Sound:
Treatment Load
Doris Cooper, Chairman
King Subregional Council
King Subregional Council • 655 - 120th N.E. • Bellevue, Washington 98005 • 206/455-7667
Draft Plan design flow for
the year 2000
Adjusted to reflect PSCOG
forecast revisions,(sub-
mitted Sept. I960)1
Less the north King County
portion of the West Point
service area
NEW TOTAL
101 mgd
108 mgd
-27 mgd
81 mgd
-------
29. Although the policy forecast does constrain sewerage
availability, it is not truly a no-project forecast. Such
a forecast would assume a lack of further expansion of
regional treatment plant capacity at the Renton plant, which
is a far greater constraint than merely limiting the avail-
ability of sewerage facilities to close-in portions of the
study area.
30. No response required.
31. No response required.
32. These forecasts have been added to Chapter 7 of the
Final EIS.
33. This comment is correct. Minor changes in population
and emissions forecasts would not require a re-evaluation
of the Metro program for consistency with the SIP.
<
34. Pollutant loading rates have been used as a rough index
of nonpoint source pollution potential in the EIS. A more
refined analysis would consider removal rates, as noted by
the comment, but such a refined analysis is beyond the scope
or needs of the EIS.
35. The additional high-growth drainage basins have been
noted in an addition to Chapter 7 of the Final EIS.
36. This correction has been made to Chapter 7 of the Final
EIS.
-------
ind CentriJ on the Park . 216 FirM Avenue South • Seattle. WA 98104 • 206/464-7090
Puget Sound Council of Governments
Grind Central OH the fvk • 216 Finl A«nu« South . Semlr. WA 9B104
February 5, 1981
Roger K. Mochnick, M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick,
9 1981
Tv g
On January 8, 1981, the King Subregional Council submitted to
you its comments on the Draft Renton Facilities Plan and Draft
EIS. One suggestion raised in the review was the use of a holding
pond to receive treated Renton STP wastewater during the low flow
period of the Duwamish River.
We are submitting a variation of this proposal which would pro-
vide additional treatment to the increase in Renton loads, but
not to the total Renton load. This could avoid what might be
an insurmountable land assembly problem.
We are asking that the attached material, together with the original
proposal, be treated as an alternative within the final EIS. The
major feature of this alternative is that it avoids the high costs
of the discharge tunnel under A, and A,, and also avoids the costs
of totally upgrading the Renton plant ^A,). In both of our sug-
gestions, the total flow handled by the Renton plant in 2000 is
reduced by routing the northern part of the proposed service area
to West Point (and possibly a later Kenmore plant).
The pivotal issues in this alternative are the actual condition
of the Duwamish River under present Renton loadings, the relative
importance of the Renton discharge compared to other point, non-
point and natural causes of pollution, and the net effect of re-
moving the total Renton discharge. On behalf of the King Sub-
regional Council, we are asking that these questions be addressed
in the final EIS.
CD
Puget Sound Council of Governments
,-iB 9 Irj81
MEMORANDUM January 29, 1981
TO: Water Resources Committee
FROM: Pete Beaulleu
SUBJECT: Renton Facilities Plan Alternatives
In the January 8, 1981 letter to EPA regarding the Draft Renton
Facilities Plan and EIS, the King Subregional Council recomnended
that the "building block" technique be used to develop additional
systemwide alternatives. One illustration, involving joint use
of a Renton area holding basin for treated wastewater--an alter-
native to the proposed Renton tunnels--was explored.
Because of the land requirements--500 acres--a second more real-
istic configuration is sketched below. Both alternatives assume
a continued 36 mgd discharge of secondary treated waste into the
Duwamish, with the new facilities handling any additional flows,
which are diminished by a further assumption that flows from
north King County (27 mgd in 2000) will not be routed to the
Renton plant.
The new alternative would provide "advanced" treatment for any
flows above the current discharge(The term "advanced" is some-
what of a misnomer since nitrification was a common treatment
step prior to the 1930's.) While extra treatment is apparently
required only during the summer time low flows in the Duwamish,
the process would be utilized continuously to avoid the operational
problems of switching the facility "on" and "off". This alternative
differs from Alternative A, only in the amount of wastewater
treated at this higher level (37.5 mgd rather than 101 mgd, in
the year 2000). It differs from Alternatives A, and A5 in the
elimination of the costly tunnel to Puget Sound:
Treatment Load
Sincerely,
Doris Cooper, Chairman
King Subregional Council
King Subregional Council * 655 - 120th N.E. • Bellevue, Washington 98005 t 206/455-7667
Draft Plan design flow for
the year 2000
Adjusted to reflect PSCOG
forecast revisions,(sub-
mitted Sept. 1980) L
Less the north King County
portion of the West Point
service area
NEW TOTAL
101 mgd
108 mgd
-27 mgd
81 mgd
-------
Water Resources Coranittee
January 29. 19&1
Page Two
Treatment Load (cont"d)
TOTAL
Adjusted to reflect
ADWT rather than
AWVTF 2
Less continued
Duwamish discharge
FINAL TOTAL
81 mgd
67.5 mgd
-30 mgd
37.5 mgd
If the nitrification process is only &5 percent effective, the
year 2000 discharge from this process, combined with the 30 mgd
discharge of secondary treated waste, would be the equivalent of
the present 36 mgd discharge.
A key issue is whether or not the present 36 mgd discharge can
in fact continue. Is the Duwamish threatened by the existing
discharge, or is it threatened by increases in this discharge?
The SRC observations on this point are addressed in the Draft
EIS critique (see attached remarks for pages 72,129 and 141 of the
EIS). Is degradation of the Duwamish due to sources other than
the Renton outfall, and secondly, does the flushing effect of
that outfall (more than) offset the detrimental effects of a
Duwamish discharge? These questions should be more adequately
addressed in the final EIS. Depending on this analysis, the
present proposal may or may noc be a workable one.
Important aspects of the proposal to treat only part of the
future Renton load beyond secondary, are the following:
(a) The site needs would not exceed two or three acres, com-
pared to 500 acres required by Bummer storage,
(b) The 37.5 mgd load could be reduced further (5 mgd) if the
secondary effluent is made available to possible solid
waste facilities , J
(c) It may or may not be compatible with the treatment needs
of future industrial customers, although pretreatment
approaches would not require a tunnel at a later date,
(d) Growth beyond the 20 year horizon might require a tunnel,
although new technologies (on site) and eventual construction
of a Kenmore plant would reduce any "need" for a tunnel at
Renton. (Such facilities could be funded by the revenue
savings.) The tunnel proposal should not be based only on
anticipated growth beyond the year 2000. This is particularly
true for long term growth in the Kenmore area.
Water Resources Committee
January 29. 1981
Page Three
(e) If a Duwamish plant is needed in the future to handle
industrial wastes, then a tunnel might be built from
that site, thus avoiding the majority of the costs of
the tunnel in Alternative Ac which passes the Duwamish
plant Bite>
(f) If secondary treatment is eventually required at West
. Point, then the assumption that this plant might be scaled
down and abandonned becomes increasingly remote, and the
rationale for routing a large part of the West Point service
area to Renton—rejected under the present proposal —is
removed.
(g) During those infrequent years when the Duwamish flow might
drop below 300 cfs, treated wastewater could be stored in
the flood water detention basin proposed by the Basin Executive
Committee in Its work with the Soil Conservation Service.
Because most of the treated wastewater would continue to
be discharged into the Duwamish, the storage needs would
be much more modest than the 500 acre figure associated
with an absolute summertime storage proposal. Joint funding
for the storage facility would require a relatively insig-
nificant contribution from Metro, but might represent the
difference between success and failure in the flood water
program.
(h) Even if the total year 2000 flow (67.5 mgd instead of lOlmgd)
is given advanced treatment, this may be preferable to the
tunnel option. To what degree can it be decided now that
the Renton plant—because of the high cost of eliminating
a Duwamish discharge—will be restricted to a certain maximum
size? Is the Kenmore plant a long term goal, and if so, can
we get by with one tunnel (at Kenmore), rather than two
(the first at Renton)?
notes :
1. Probable revisions to the PSCOG forecasts include a 6 percent
increase in the year 2000 population for King County.
2. Average Dry Weather Flow is the appropriate figure for
dealing with the low flow period In the Duwamish. A ratio
of 5/6 is derived from data on page 109 of the ELS.
3. Solid waste facilities require 350 to 2000 gallons per ton.
The daily 1986 tonnage will be 3700 (1.3 to 7.4 mgd).
4. Of the "tunnel" cost (198 million dollars, only 50 million
dollars is for the tunnel Itself(Draft Plan, p. 72).
-------
Response to PSCOG Letter of February 5, 1981
1. Elements of the PSCOG proposal have been evaluated in
the Final EIS, in that the final plan recommended program
evaluated in the EIS does assume that the Renton plant will
not treat flows from the north part of the service area.
Although the PSCOG proposal would reduce threats to the Green/
Duwamish River water quality and aquatic biology, EIS analy-
sis of the impacts of the existing discharge (which is about
40 MGD rather than 36 MGD), and the impacts of a nitrified
discharge, indicates that diversion of the projected year
2000 flow of 73 MGD from the Renton service area to Puget
Sound is still justified to avoid adverse impacts on the
Green/Duwamish River.
2.
See General Response Number 3.
3. In order to remove ammonia (through nitrification) from
only future flows, essentially two separate treatment systems
would be constructed. The existing 36 MGD liquid stream
plant would continue to operate in a secondary treatment mode,
while expansion to 72 MGD and subsequently to 99 MGD would
be accomplished by adding components to achieve nitrification.
Since the ammonia conversion process is a biological one,
a specific population of micro-organisms must be maintained.
This necessitates separation of the secondary systems. Primary
treatment would also be segregated since alkalinity dosing
would be required prior to nitrification in order to maintain
suitable pH levels.
Primary solids and waste sludges from both secondary
systems could be processed in the same solids handling facili-
ties. As with the other Renton plant options gravity thickeners
would be used for primary solids, and dissolved air flotation
for waste-activated sludge. Both sludge streams would be
stabilized in anaerobic digesters and then dewatered.
Operation of the Rention plant in this partial nitri-
fication mode would add a significant degree of complexity
to plant functions, and disproportionally increase staffing
and laboratory requirements. The increased complexity would
also affect "reliability" such that the probability of process
upset is increased. Estimated costs for a partial nitrifi-
cation alternative treating 99 MGD by the year 2000 are $237.4
million in present worth terms. This is $41.6 million cheaper
than Alternative A-l and $29.6 million cheaper than Alterna-
tive A-3. However, the key point is that this alternative
requires continued discharge of 36 MGD advanced secondary
effluent to the Duwamish River. In the judgment of water
quality and fisheries agencies, including EPA, this would
not provide acceptable protection for water quality and
fisheries.
4. See General Response Number 3. Fishery resources are
threatened by existing discharge levels. EPA water quality
criteria are being violated, and conditions would become
lethal to salmon if high pH algal blooms were to occur.
Such blooms have occurred in the past, under conditions of
lower treatment plant flow, and there is no basis for pre-
dicting they will not occur in the future. The Final EIS
analyzed the flushing effects of the discharge, and the cumu-
lative impacts of other activities in the watershed on water
quality.
5. Potential reductions of this magnitude in the volume
of treated effluent requiring discharge do not represent
alternatives to the overall concept of marine discharge.
At best they might delay the need for marine discharge
facilities.
6. Metro's preliminary plan compared alternatives with
one tunnel from a Kenmore plant and with two tunnels from
Kenmore and Renton plants. The former was less expensive,
assuming advanced secondary treatment at Renton with Duwamish
discharge. However, that strategy would not completely pro-
tect Duwamish water quality. When nutrient removal was added
to the Renton treatment, the one-tunnel alternative becomes
more expensive than the two-tunnel alternative. This does
not consider the impact of inflation on operation and main-
tenance costs, which would further favor tunnelling over
advanced treatment.
7.
See General Response Number 9.
8. A final decision as to whether to reroute flows from
the West Point service area to the Renton plant has not been
made.
9. The Kenmore plant remains a long-term option in Metro's
final plan.
-------
KIRKLAND
210 MAIN STREET KIRKLANO. WASHINGTON 98033 (2061832927!
JAN
19S1
I
CITY OF
January 28, 1981
Mr. Roger K. Mochnick
H/S 443, Environmental Evaluation Branch
U. S. Environmental Protection Agency
1200 6th, Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
Thank you for the opportunity to review the Draft Environmental
Impact Statement for Metro's Waste Water Management Plan for
the Lake Washington/Green River Basin. After reviewing this
document with my staff," we find that we have no substantive
comments to make at this time.
However, we would like to express our concern that the resource
recovery alternatives for sludge disposal have not been inclu-
ded as part of the recommended alternatives. We feel that this
is a significant aspect of any waste water management plan and
.stiould be an integral part of the final adopted proposal.
Once again, thank you for the opportunity to comment on this
project.
Sincerely,
DEPARTMENT OF.COMMUNITY DEVELOPMENT
Response to City of Kirkland Letter of January 28, 1981
1. See General Response Number 5.
/ \ /
Uos*epp Tovar
ftctjing Director
SW:bJ
-------
HIGHLINE PUBLIC SCHOOLS SCHOOL DISTRICT 401
EDUCATIONAL RESOURCES MX) ADMINISTRATIVE CENTER
IS«71 Amb#om BouW*«>d SW • T*l*ptx>ro • 2O*/«33-OI11
February 5, 1981
Mr, Roger Mochnick
Mai] Stop 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98104
RE: Draft Wastewater Management Plan, Lake Washington/Green River
Basins (Renton 201 Study).
This letter is in response to the proposed Draft Wastewater Management
plan described in the Renton 201 study as Alternative A-3. This alter-
native proposes to deposit the effluent discharge into Puget Sound near
Point Pulley and the Seahurst Park area.
Since 1968 the Occupational Skills Center has operated the Marine Technology
program at Seahurst County Park. It is cooperatively owned and operated by
the Highline, Federal Way and South Central School Districts. Each school
year the program provides 400 hours of vocational training for forty high
school students interested in pursuing a marine related career. This in-
cludes such fields as hatchery management, water quality control, ocean-
ography, marine biology and aquaria operation.
The salt and non-chlorinated stream water systems made possible by the
shoreside location of the facility, allow students to develop marine related
skills and knowledge through direct experience. In addition, the water
systans are used in conjunction with group tours, special classes, and a
small number of research projects. Public viewing aquaria, a conditional
part of the lease of the land at Hunro Seahurst Park, are made pos-sible by
the two systems.
The sea water system consists of two parallel three inch diameter plastic
suction lines extending west from the Marine Tech lab about nine hundred
feet from the bulkhead. From a depth of twelve to thirty feet, a volume
of twenty-five to forty gallons per minute of sea water is pumped into the
lab. Only one suction line is used at a time. Fresh stream water is back-
flushed down the other line to kill marine fouling organisms which would
soon reduce, then stop the flow. The linesare alternately used for suction
and back-flushing and are cycled on a weekly basis.
-2-
The program and facility also includes a small salmon hatchery, a cooperative
program licensed by the State Department of Fisheries. Since 1972 Coho and
Chinook salmon have been incubated, reared and released alona the beach at
Seahurst Park. The annual return of mature Coho salmon to the fish ladder
and small holding pond in the two hundred g.p.m. stream adjacent to the lab
is a community event. In December 1980, over one hundred fifty salmcn pro-
vided ovor one hundred twenty thousand eggs. Under the direction of state
fisheries biologists the students will plant excess Coho fry in nearby
streams. Fishermen have found the bay off Seahurst to be increasingly pro-
ductive.
Biological sampling and fishing methods are taught, using a one hundred
twenty foot beach seine, ten foot otter trawl, biological dredge, plankton
and dip nets. A variety of standard oceanographic instruments are used to
sample the water and sea bottom.
Several articial reefs are located one thousand to fifteen hundred feet off
shore from the Marine Tech lab. They are very popular with scuba divers ar.c
fishermen, and have been used for marine studies in previous years.
The Highline School District is very concerned that the proposed alternative
will negatively impact the Marine Tech program.
Due to run-off, there is a total net flow of water out of Puget Sound at the
surface. However, the circulation of East Passage (the channel between High-
line and Vashon Island) south of Alki Point is southerly, and very sluggish.
This means that effluent would have a long detention time and flush out of
Puget Sound only after circling Vashon Island. Locally a complicating factor
is the back eddy which sets north from Three Tree Point along the near shore
area toward Seola Beach. One concern is that the less dense effluent will
migrate toward the surface, circulate around in a counter-clockwise direction
and become concentrated by the onshore winds in the near shore region off
Seahurst. Although treated, the effluent could add heavy metals and toxi-
cants to the receiving waters. Even though tests anticipate the proper dis-
posal of effluent, it appears that as the discharge of 100 million gallons
per day, and an ultimate discharge of 140 million gallons per day continue,
it will undoubtedly impact the area. With sensitivity of the Marine Tech
program, a short term system malfunction, or addition of toxic materials
by accident, could have a negative impact that might take years to overcome.
The Seahurst Park area has a southwest to northwest exposure with prevailing
onshore winds. If this wanner liquid from the sewer effluent rises to the
surface it will come ashore in the Seola Beach to Three Tree Point area.
This will impact not only the Marine Tech program, but the recreational use
of Seahurst Park.
The Highline School District suggests that other alternatives, which have a
much lesser potential negative impact on the local area, be considered.
Sincerely.
(1)
.^Robert 0. Sea ley
r Superintendent
FtB VO 1981
RDS/dgb
-------
Response to Hiqhline Public Schools Letter of February 5,
1981
1. The discharge of treated effluent should not affect
salmon rearing facilities because salmon are reared in fresh-
water supplied from a nearby creek. Scientific evidence
indicates that minute concentrations of treated effluent
in marine waters will not affect the adjustment of released
salmon to saltwater, nor the homing instincts of returning
salmon.
2. Metro's engineering consultant reports that the outfall
can be designed so as to avoid the artificial diving reef.
3. The Final EIS finds that although diluted effluent may
infrequently approach beaches, the concentration would not
be great enough to affect shellfish, public health, or other
beneficial uses. Also, the frequency of diluted effluent
surfacing is predicted to be less at Seahurst than at Alki
Point (see General Response Number 1).
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King County, Stale of Washington
Ron Dunlap. County Executive
Department of Budget and Program Development
Room 400 King County Courthouse
516 Third Avenue
Seattle. Washington 98104
John M Rose. Director
(206)344-3434
February 10, 1981
FEE 19 1981
BWIMWMENTAL tVWJJfilWN
BftMtCH
Roger K. Mochnick
Cnvjronmental Evaluation Branch
U.S. Environmental Protection Agency
M/S 443
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Mochnick:
Several county agencies have reviewed the draft environmental impact
statement on the Draft Wastewater Management Plan for Lake Washing-
ton/Green River Basins. King County's Environmental Impact Committee
has also reviewed the statement and the responses from County depart-
ments. As chairman of the County's Environmental Impact Committee,
I am transmitting the results of these reviews as a consolidated re-
sponse from King County.
Our comments are organized according to various subject headings to
facilitate your review and response.
Assumption About Future Sewage Needs
The Wastewater Management Plan states that most facilities are
planned to meet sewage needs for a twenty year period. The plan
and the EIS clearly show how most facilities are designed for the
population expected to locate within the current sewer local service
area in the next twenty years, as forecast by the Puget Sound
Council of Governments. However, in the preferred program,
some facilities will be sized to meet sewage flows for fifty years.
How are the fifty-year flows calculated, and what assumptions are
made about the non-sewer area where land use is considered
"uncertain"? Is it assumed that fifty years growth will locate
within the current local service area, or that new acreage will be
sewered?
The plan states that dual sewage treatment facilities would provide
more flexibility to respond to changing population distribution. In
choosing the centralized facility, rather than dual facilities, what
is the cost of losing that flexibility? The plan asserts that, in
some cases, it is more cost effective to build a fifty year facility
than to build a twenty year facility. In those cases, the assump-
tions behind the planning and decisions to build a longrange
facility should be spelled out, so that the risks and the possible
benefits, including potential cost saving can be examined.
®
Roger K. Mochnick
February 10, 1980
Page 2
The Plan points out the uncertainty about future land use plans,
the magnitude of population growth, and the expected location of
population growth within the study area. What degree of flexi-
bility does Ihe preferred program have to respond to changing
land use plans?
Predictability and Funding
The DEIS and Plan describe an extensive list of additional studies
that are necessary prior to final design decisions on the selected
alternative. These studies, some of which will require a year to
complete, are planning level investigations that are normally con-
ducted prior to the selection of alternatives, rather than "con-
firming" studies that are part of the final design process (e.g.,
geologic, oceanographic and engineering studies). The extent and
timing of the required additional studies raises questions regarding
the predictability of the tunnel alternatives as compared to other
options, especially alternative A-1.
Tunnel alternatives also require land and easement acquisitions and
are subject to additional permitting actions (shoreline permits, 404
permits for spoil, etc.) and potential legal action. Variables and
unknowns resulting from the studies, land negotiations and permit
processes could dramatically affect project design, project costs
and possibly the feasibility of the preferred program. The final
environment impact statement should discuss predictability as a
function of its effect on the "ability to implement" each alternative.
Further the final statement should identify the process for re-
evaluating the selected plan, should major problems make it in-
feasible or impractical.
The availability of state and federal grants, particularly Section
201 construction grant funds, is a major economic factor affecting
the implementation of any alternative. It would appear that alter-
natives which require considerable additional study would tend to
jeopardize opportunities to capture 201 funding. The final environ-
mental impact statement should more thoroughly describe the lead
times required for each alternative prior to construction financing
and the relative degree of risk associated with uncertainty and
delay and the potential effect on funding opportunities.
Spoil disposal
The issue of spoil disposal should be expanded in the final EIS to
discuss more specifically how approximately 200,000 cubic yards of
material from tunneling will be moved and ultimately disposed of.
Consideration should be given to the preparation of a spoil dis-
posal management plan because of the significant quantity of ex-
cess spoils and time involved to move the material (i.e., 47 trucks
per day over an 85 week time period) and the potential impacts
related to earth movement and disposal. The statement should deal
with the questions of alternative disposal sites and impacts at
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Roger K. Mochnick
February 10, 1980
Page 3
those sites; methods of removal and haul routes for transporting;
required permits; costs of disposal including site acquistion costs,
transportation costs, fees for disposal; and should discuss prob-
able beneficial uses (i.e., landfill, cover material at solid waste
sites, etc.) and opportunities for such uses to offset disposal
costs.
Impact on South Puget Sound
More information is needed regarding effluent dispersion, effluent
residence time and cummulative water quality impacts on South
Puget Sound from a Point Pulley outfall. The draft EIS notes that
net circulation patterns at Point Pulley will draw diluted effluent
further south in the Sound and around Vashon Island before
transport out of the system. Effluent will be mixed with storm-
water runoff and industrial discharges entering Commencement Bay
from Tacoma.
The EIS should discuss how this added increment of sewerage
effluent will affect the water quality balance of South Puget Sound
which currently is stressed and has been documented as an area
--evidencing chemical contamination and biological abnormalities
(NOAA Technical Memorandum OMPA-2, Nov. 1980). The statement
should discuss the potential for maximum pollutant loading as a
result of plant failures and spills both within the system and from
external sources and the immediate impacts to localized areas as
well as cumulative impacts on South Puget Sound.
Information should also be provided to document the impacts of up
to 30% of the diluted effluent permanently encircling Vashon Is-
land, particularly to areas such as Quartermaster Harbor where
tidal flushing is slow, or to areas where eddy currents may retard
water replacement such as between Point Pulley and Point Robin-
son. If possible, information should also be presented on the
relationship of nutrients and the red tide.
Effect on the Green/Duwamish
The water quality analysis of the alternatives overlooks the impact
of further reduction of the Green/Duwamish River low flows by
elimination of Renton effluent discharges and the benefits of pro-
perly treated discharges as flow augmentation. Renton discharges
could comprise of up to 25% of the total volume of the river at
point of discharge. The net effects on water quality should be
the primary consideration. For example, the draft environmental
impact statement claims that improvement in dissolved oxygen (DO)
will occur if the Renton discharges are eliminated, but does not go
on to state that lower flows could aggravate the low DO problem
by allowing the salt water wedge to position itself further up the
Duwamish. To what extent are they offsetting?
The relationship of DO and the wedge was a concern raised in
RIBCO and in a February 25, 1980 a letter fom Metro to the De-
Roger K. Mochnick
February 10, 1980
Page 4
partment of Ecology. In the same letter Metro called for the
establishment of a minimum streamflow of 250 cfs higher than that
proposed by the state. Yet the Metro preferred alternatives
reduce total river flows by up to 150 cfs by the year 2000. Is
this consistent? Has the value of reclaiming and reuse of waste-
water been underestimated? The final environmental impact state-
ment should state how the directives of the Clean Water Act for
consideration of beneficial uses of reclamation and recycling of
wastewater is addressed in Metro's planning. Decisions on the
Renton plant should assure that water quality and water resource
management objectives for the Green/Duwamish system are consis-
tent and mutually supportive.
The four final alternatives appear to be "all or nothing" options
with little or no flexibility for management and operation vari-
ations. For example, advanced treatment with nitrification could
be utilized during the low flow period only. The majority of the
plant expansion would therefore be for advanced secondary (similar
to existing capability and also needed in alternatives A-3 and A-5)
with only the lowest volumes during three low flow months re-
quiring nitrification. RIBCO briefly discussed this approach (p.
78, Part III, Water Quality) and mentioned breakpoint chlorination
and dechlorination, addition of lime to the primary clarifier, as
well as nitrification as alternatives for removing nitrogen com-
pounds. Addition of lime was the least-cost treatment process
alternative. A seasonal treatment option should also be addressed
in 201 planning and in the final statement.
Several major mitigation possibilities appear to have been over-
looked. First, temperature standards violations will likely continue
as a problem in the system regardless of which alternative is
implemented. River shading and flow augmentation are possible
means to address this problem and should be more thoroughly
explored. These measures may be more possible than previously
considered since local governments have made a renewed commit-
ment to preserve riverside areas and the Corps of Engineers is in
the process of reassessing Howard Hanson Dam's operations.
Second, if the major concern behind the alternatives which elimin-
ate the Renton discharges from the river is the fisheries resource,
then an option should be formulated which allocates the $110 to
$198 million associated with tunnels to Puget Sound to a fisheries
impact mitigation program. Such a program may even include the
consideration of an exclusive fish passageway which is separate
from all polluted water, whether Renton discharge related or not.
P-1 Drainage Channel
The Renton Treatment Plant layout as identified on page 64 of the
Plan shows the P-1 drainage channel bordering the plant on the
east and north boundaries. North of the plant the alignment of
the P-1 channel has been modified and no longer follows the 300
foot property easement to the Black River pump station as shown.
The channel now parallels the corridor of Springbrook Creek
(10)
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Roger K. Mochnick
February 10, 1980
Page 5
Roger K. Mochnick
February 10, 1980
Page 6
northeasterly from the north boundary of the Renton Plant to a 25
acre holding pond immediately upstream of the pump plant. In
this configuration, the permanent channel right-of-way has been
reduced from approximately 300 feet to 210 feet in width. Some
additional land next to the channel will be required temporarily for
storage of excavated spoils from channel construction. Construc-
tion of the channel and pond in this area (e.g., pump station to
1-405) is scheduled to begin in summer of 1982.
This design for the channel project eliminates potential conflicts
with channel right-of-way and expansion of the Renton plant. If
constraints to plant expansion were considered factors which
reduced the desireability of Alternative A-1, or some variation,
this change should be taken into consideration in the final EIS.
Seahurst Park
We do not agree with the statement on page 153 of the EIS that it
is unnecessary to determine which alternative is "best" from a
recreation perspective. To the contrary, determining the projects'
impact on existing recreation facilities may clearly demonstrate a
preference for one alternative over another A case in point
exists at Seahurst Park.
Seahurst Park is considered a model saltwater park that was de-
signed and developed with Forward Thrust and state matching
funds after lengthy debate with the community. The park has
extremely high visitor use, particularly during summer months. A
marine biology lab and fisheries facility of the Highline School
District is adjacent to the park and diving reefs have been con-
structed by State Parks to promote near-shore scuba diving.
Disruptive construction related impacts noted in the EIS for the
Route A tunnel, highly sensitive geologic conditions, and effluent
discharges in close proximity to swimming and diving beaches, are
impacts that cannot be overcome by mitigation or enhancement
efforts. We therefore recommend that the Seahurst tunnel and
outfall alternative be eliminated from further consideration.
Planning for the Non Sewer Area
Metro's role in the non-sewer area is unclear. The plan recom-
mends a program for local governments to follow; they are ex-
pected to collect information about water quality problems in the
non-sewer area, and to meet with health departments to make
decisions about actions to correct those problems. Local govern-
ments and health departments now have the authority to correct
problems which they identify. What will Metro add to this system?
Is a change in authority contemplated?
The recommended program for the non-sewer area raises questions
about funding for on-site systems and programs. The Plan en-
courages experimentation with alternative wastewater technologies
in the non-sewer area, but the EIS states that no funding is being
sought at this time. Will Metro seek funding later to develop
alternative technolgies which can be more cost-effective in low
density applications? Is the plan a Step 1 '201' plan for the
non-sewer area? How will the plan affect funding opportunities
and priorities for alternative and innovative technologies for the
non-sewer area?
Besides the major questions about Metro's role, the plan also raises
questions about the relative costs and effectiveness of the recom-
mendations for non-sewer areas. There are few facts included in
the draft EIS to justify the recommended program. To what extenl
would each element of the recommended program for the non-sewer
area contribute to water quality and public health? Which elements
are essential and which are simply desireable? Do the recom-
mended methods produce results which justify the costs? For
example, what is the effect of regular septic tank inspection on
preventing failures and preserving water quality? Does the effect
justify the costs of mandating regular inspections?
The standards to be used for the "triggering mechanism" should
be discussed in the final plan. What evidence of on-site problems
or frequency of on-site failures will be considered significant
enought to point to the need for action?
Energy Considerations
Since the preferred program requires more electricity per gallon of
sewage than some of the other alternatives, the EIS should clarify
what assumptions are made about future energy supplies and
costs. Today's electricity prices do not necessarily reflect the
price of future electricity, and future supplies of electricity are
not as certain as present supplies. How were these facts incorp-
orated into the selection of the preferred program? What measures
can be taken to ensure future energy supplies, or to generate
energy at the treatment plants?
Sensitive Areas
The EIS has noted that some of the planned facilities in the pre-
ferred program will cross wetlands, floodplains, and County
agricultural districts. What techniques have been developed to
insure that construction and growth impacts can be mitigated in
these areas? Are Metro's project plans and facility routes flexible
enough to change if the project-level environmental impact state-
ments indicate that the adverse effects of construction and location
of sewer facilities in these areas cannot be avoided?
Impacts to Surface Water Systems
The draft EIS properly notes the cause-effect relationship of
sewers, increased development and surface water runoff. How-
ever, as witnessed in the case of the May Creek interceptor 201
project, this relationship and resultant impacts can be a major
(18)
(19)
(20
(21)
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Roger K. Mochnick
February 10, 1980
Page 7
factor in project related decisions, timing, form of mitigation, and
whether project-related EIS's are required. Therefore, stronger
relationships between wastewater management and surface water
management should be established along with parameters to help
identify in advance when wastewater project decisions will be
particularly sensitive to surface water systems. In addition, since
gravity sewer lines generally follow rivers and streams and must
cross them, construction related and permanent impacts should be
identified.
We appreciate this opportunity to comment on the draft environmental
impact statement. Decisions related to wastewater management will be
some of most important for the region in terms of environmental con-
sequences and financial burden. The manner in which the Environ-
mental Protection Agency considers comments on the draft environmental
impact statement, therefore, will directly affect how expeditously the
decisionmaking process can move toward implementation. We look for-
ward to the reponses to the issues and questions that we and others
have raised and to continuing participation in programs to provide the
best practicable wastewater management for our growing area.
Sincerely,
dohn M. Rose
Chairman, Environmental Impact Committee
JR: mm
Jack Lynch, Planning & Community Development
Sheila Manus Vortman, Program Development Division
James Guenther, Public Works
Harold Robertson, Planning Division
John Nordin, Health Dept.
Jeff Bauman, Metro
Pete Beaulieu, PSCOG
Response to King County Letter of February 10, 1981
1-2. Only the proposed tunnel/outfall to Puget Sound and
the Redmond connection-North Creek/Hollywood connection have
been sized for 50-year flows,
The tunnel/outfall is sized to match the ultimate capa-
city of the Renton treatment plant, namely 144 MGD average
flow and 325 MGD peak flow. The 50-year (2030) average
flow for the Renton treatment plant is projected to be 146
MGD. The 50-year flow projection is based on a revision
of population and flow estimates originally prepared for
Metro's 1958 comprehensive plan. The Redmond connection
and North Creek/Hollywood connection are similarly sized
for the 50-year flow pro3ected for their tributary areas.
The projected sewered population and sewered acreage is
distributed among major drainage basins. Whether the addi-
tional growth will locate within current local service areas
or within an expanded service area is a decision to be made
by the appropriate land use agencies. Metro made no specific
geographic assumptions about where the additional growth
will locate.
Choosing the centralized alternative (A-3/A-5) does
not foreclose the option of building a Kenmore treatment
plant in the future. Metro analysis shows that about the
year 2020, when the Eastside interceptor reaches capacity,
a decision point will be reached where a Kenmore treatment
plant should be considered. While it is not now cost-effec-
tive to construct a Kenmore treatment plant, the Renton 201
Citizen's Advisory Committee and others have suggested that
Metro obtain a 40-acre site in the Kenmore area to preserve
the Kenmore treatment plant option for the future. Addi-
tional information on sizing of nonmodular facilities is
provided in Chapter 2 of Metro's Final Plan.
3. Changing land use plans may affect the timing of imple-
mentation of the modular elements of the recommended program
but would not alter the major decisions being made for near-
term improvements.
4. See General Response Number 15. Regarding the effects
of "ability to implement" on project costs, see General Response
Number 19 to PSCOG letter of January 8, 1981.
5. Additional information on construction timing and funding
availability is presented in Metro's final Facilities Plan
in Figures 3-10 and 3-11. Construction of all components
of the project is estimated to begin in 1984 and be completed
in 1986. Effects of possible project delays, from any cause.
-------
or. funding availability cannot be predicted at this time.
However, both EPA and Washington State DOE intend that funding
be provided only for a complete project that includes com-
pletion of all project components.
6. Additional detail has been provided regarding spoils
disposal in Chapter 5 of the Final EIS. EPA will recommend
chat Metro develop a spoils disposal plan, as suggested by
King County.
7. .See General Response Number 2.
8. The Renton treatment plant is a well run and well main-
tained facility. The existing plant began operation in 1965
and has never experienced a serious process upset. Like
the existing facility, the expanded treatment plant will
be designed with several backup and contingency measures
to provide a high degree of reliability. Backup mechanical
equipment, the resiliency of the secondary biological process,
and enough primary capacity to isolate high strength "slug"
flows are some of the contingency measures that will make
a process upset or plant failure highly unlikely. In the
unlikely event of a failure in the Renton plant secondary
process, primary treated effluent would be temporarily dis-
charged from the outfall, rather than secondary treated
effluent. This would result in a decrease in plant performance
from 90 percent removal of suspended solids and oxygen
demanding materials (BOD,) to about 30 percent removal of
BOD^ and 60 percent removal of suspended solids. Failure
of the primary treatment process is extremely unlikely
because of the mechanical simplicity of the system.
More sophisticated treatment levels are more prone to
upset, raising the likelihood that effluent treated only
to primary levels would be discharged, in this case to the
Duwamish River, a more sensitive receiving water. Impacts
in such an event would depend on timing, but could include
fish kills and severe water quality standards violations.
9.
See General Response Number 3.
10. Analysis in the Final EIS indicates that, although wedge
dissolved oxygen may be slightly decreased by removal of
Renton effluent, this negative effect is more than offset
by the positive effects of removing Renton wasteloads from
the Green/Duwamish River. Stream flow augmentation is an
important beneficial use of effluent in the abstract, one
which EPA policies support, but its benefits in the case
of the Green/Duwamish River appear to be outweighed by the
detrimental effects of wasteloads in the effluent on the
river.
11. Land application of Renton effluent was considered for
six decentralized plants in the Draft Plan, and was found
to have few benefits justifying the increased costs. Large-
scale land application was determined to be infeasible because
of excessive land requirements.
12. See General Response Number 4b to U. S. Army Corps of
Engineers letter and General Response Number 3 to PSCOG Letter
of February 5, 1981.
13. See General Response Number 11 to Department of Game
letter.
14. The Final EIS points out that fishery mitigation is
not possible since hatchery capacity is not available. The
cost of constructing a fish bypass channel would be similar
to the cost of constructing the Alternative A-5 effluent
pipeline along the Duwamish. Thus a fish bypass channel
would be more expensive than the Seahurst Park tunnel. In
other words, it does not really offer a cheaper solution
to the problem. There are also questions about the technical
feasibility of a fish bypass channel, including whether enough
water exists for both the natural river channel and the bypass
structure and whether all salmon and steelhead would use
the bypass channel. The river would essentially become a
conduit for Renton treatment plant effluent. Thus the resi-
dent fishery and the juvenile rearing habitat (anadromous)
would be lost. This alternative would probably be unacceptable
to DOE and Department of Fisheries.
15. The original channel alignment was not a constraint
to treatment plant expansion.
16. Impacts of the tunnel/outfall construction at Seahurst
Park have been described in further detail in Chapter 5 of
the EIS. Although substantial short-term construction impacts
will occur, as described in Chapter 5, no long-term impacts
on beneficial uses of Puget Sound coastal waters are predicted,
as discussed in General Response Number 2 and Chapter 6 of the
EIS. Also see response to Highline Public Schools letter.
17. Metro sees its role in the nonsewer area as that of
a regional agency seeking to solve water quality problems
stemming from the inadequate performance of on-site wastewater
systems. Information of septic system performance supplied
by the Health Department will be coupled with Metro water
quality data to identify areas where existing on-site system
performance may be inadequate from a community wastewater
management standpoint. By identifying these areas and pro-
viding a forum for key local agencies to discuss these waste-
water disposal deficiencies, Metro hopes to resolve existing
problems before on-site or community wastewater systems are
no longer viable options.
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Metro sees its role in this program primarily as a
facilitator, with responsibility for on-site wastewater pro-
grams lying with local health and land use agencies. EPA
has recommended that Metro take an active role in seeking
implementation by land use agencies of needed recommendations
for on-site systems.
18. See General Response Number 21 to PSCOG letter of
January 8, 1981.
19. . See General Response Number 4 to PSCOG letter of January
8, 1981.
20. Energy/chemical costs were one of the cost criteria
used to evaluate alternatives. Metro also considered the
effect of inflation, which disproportionately affects energy
costs, on alternative ranking. Metro found that at inflation
rates greater than 3 percent, the Seahurst Park alternative
became cheaper than the Duwamish discharge alternative.
Metro's recommended program calls for sludge digestion and
methane recovery to produce energy at the treatment plant.
21. See General Response Number 6.
22. EPA agrees that growth-related surface water impacts
of sewering decisions must be considered. The EIS provides
an areawide overview of potenti^iximpacts. These impacts
will be further considered in project-specific EISs and in
Metro's proposed triggering mechanism.
23. Construction and permanent impacts of individual sewer
projects on rivers and streams are best identified in project-
specific EISs.
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Post Office Box 1 768 - Bellevue, Washington • 98009
February 13, 1981
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
120U Sixth Avenue
Seattje, WA 93101
FEB 17 1981
ENVIRONMENT*! .^"^-
Re: Draft Environmental Impact Statement
Wastewater Management Plan for the Lake Washington/Green River Basins
Dear Mr. Mochnick
The City of Bellevue has reviewed the draft Environmental Impact Statement
(EIS) for the Wastewater Management Plan for the Lake Washington/Green River
Basins and appreciates the opportunity to comment. Our major concerns are the
need to hold down the cost of service to users and have adequate wastewater
management facilities, including interceptors pump stations and force mains
available while maintaining and improving environmental quality. The
following are detailed comments on the draft EIS and the companion draft plan
related to these concerns:
SUING OF NON-MODULAR FACILITIES
We recommend including in the plan a statement of policy that was discussed by
Metro but which is not clearly stated irNthe Plan or EIS, namely: Facilities
to serve future increased demands, such as interceptors, should be sized to
accommodate long term needs where construction cannot conveniently be staged.
NEEO FOR REGIONAL WATER RESOURCES PLANNING
On page 129 of the draft EIS, there is a statement that reads, "the DOE (1980)
has recently adopted rules calling for minimum flows of 300 cfs. in the Green
River at Auburn. Present low flows are about 200 cfs. There is not yet any
clear agreement on how additional flows will be gained. This statement
highlights the need for water resources management to be planned in the
context of tne three county needs related to water supply, flood control, and
tne treatment of sewage. To urther, minimum flows in the
Green/Duwamish River are affi ._ loward Hansen Dam Operation and by the
water supply needs of the City of Tacoma, and other municipalities. Also,
flood control ponding proposed in the Green River Valley might conceivably be
used to store treated effluent from the Renton plan during river low flow
periods and discharge during higher flow periods. Therefore, by coordinated
planning for increasing actual low flows in the river and discharging less
effluent the reasoning behind the overruling decision by Metro to get the
effluent out of the river might be changed.
City ol Bellevue offices are located at Mam Street & 11 6th Avenue S.E.
We contend therefore that before going ahead and spending hundreds of millions
of dollars on wastewater management improvements, all water resource
management needs should be addressed 1n a composite program of most benefit to
the residents of the three county areas.
MIDDLE GROUND TREATMENT METHODS
In the draft EIS the proposed methods of treating wastewater range from
sophisticated advanced treatment methods before discharging effluent into the
river to secondary treatment and discharging treated waste into Puget Sound.
Both of these options would be very expensive to implement. The draft EIS
does not and should address, middle ground solutions which might incur less
cost at the Renton plant, e.g., storing treated affluent in a holding
reservoir during river low flow seasons and subsequent controlled discharge
into the river when flows are higher.
METRO SrSTEMWIDE ALTERNATIVES
In using the "building block" approach of meeting future needs by building
modular waste management units, Metro has considered the Renton Treatment
Plant and the area served by it in isolation. The other treatment plants
which are located on Puget Sound were covered under a separate 201 plan and
have not been considered in this latest plan for the Renton Treatment Plant.
Therefore, planning to meet the needs of the Metro served area has not been
done in the most cost effective way. It is recommended that the alternatives
of not closing Alki Point and Carkeek Plants should be reviewed in the EIS
since with this option the West Point Treatment Plant could take waste
diverted in the proposed plan to Renton via the Redmond connection and
therefore reduce costs.
COST OF ENVIRONMENTAL PROTECTION
The detailed Impact of future discharge into either the Sound or the Duwamish
River and the benefits of costly mitigation of "harmful" effects are not well
covered in the EIS. The specific environmental benefits such as protection of
fish runs and recreational shellflshing are not that apparent in the EIS.
Since protection of these resources could result in the expenditure of
millions of dollars, additional documentation would seem important. The data
base available on the Sound and used in the EIS is limited to information
about the West Point outfall; the significance of heavy metals in the Duwamish
River discharge awaits the completion of a Toxicity Study; and the sludge
management method finally to be adopted will not be known until another study
ends. In short the EIS should tell us what we are buying with these expensive
facilities and processes in more specific terms.
DUAL PLANT ARRANGEMENT BENEFITS UNDERPLAYED
Alternative Bl which 1s a dual treatment center alternative, whereby the
Renton Plant will continue to serve the existing Renton service area and a new
Kenmore Treatment Plant will serve the north part of the study area currently
tributory to West Point, is not considered in the EIS with respect to the
important operational benefit of having multiple plants rather than one single
plant serving the Renton area. Another advantage of the dual plan is that
(4)
-2-
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both plants, Renton and Kenmore, would be capable of expansion 1n the future
thus Increasing the options for serving a larger wastewater management demand
should one arise.
TRIGGER MECHANISM NEEDS INSTITUTIONALIZING
The so called "triggering mechanism" which is to act as a timing device to aid
in the implementation of the modular elements of the long term program to meet
the needs of future growth and changes in water quality and wastewater flows
is assumed to be the responsibility of the agencies which have land use
control in any particular geographic segment of the Metro served area. We
agree with the comments made in the letter in response to the draft EIS from
the Puget Sound Council of Governments that local inaction in dealing with
water. quality issues identified through the triggering mechanism or other
means can take the decision making on how to plan and implement incremental
waste treatment facilities away from local government. We recommend therefore
that the institutional aspects of the so called triggering mechanism be worked
out in detail in advance so that responsibilities and a method of coming
together for decision making is already in place before the event. Thus, the
201 plan should include a management system including procedures or formal
agreements to insure that the necessary monitoring activities are considered
and that affected jurisdictions meet together periodically to review the need
for updating Metro plans.
FISCAL IMPACTS TREATED SUPERFICIALLY
Tne fiscal impact of the alternative plans are not considered in the draft EIS
in nearly the same depth as the environmental impacts. In order to provide
equitable distribution of costs there should be an allocation of costs and of
system capacity to indicate the amount that is set aside for each recognizable
jurisd>ction. This will make it possible to compute what additional costs
could be allocated to future users of the Metro system outside the current
sewered area. In this way it would be possible to determine the allocation of
costs for new developments that could be made in order to insure an equitable
contribution by these new users to the Metro system as a whole.
Finally, we would compliment Metro, EPA and the authors of the EIS on a
thorough and professional job.
Sincerely
Diane T. White
Environmental Coordinator
9060C/SE
(8)
-3-
Response to City of Bellevue Letter of February 13, 1981
1. See General Response Number 1 to King County letter.
2. See General Response Number 3.
3. See General Response Number 4b to U. S. Army Corps of
Engineers letter and General Response Number 3 to PSCOG letter
of February 5, 1981.
4. Metro's recommended program has incorporated this system-
wide cost-effectiveness approach.
5. Additional documentation of the benefits and impacts
of Metro's recommended program has been provided in the Final
EIS. The value of the Green/Duwamish River fishery to be
protected by the recommended program is now estimated to
be over 510 million annually. Additional data nave also been
provided regarding Puget Sound and Green/Duwamish River impacts
of the recommended program. It is true that Metro's toxicant
study and sludge management plan will not be completed until
after a decision regarding the wastewater management plan
is made. However, adverse impacts on the Green/Duwamish
River will occur if a decision is delayed for several years,
and results of these studies are unlikely to modify decisions
regarding expansion of the Renton plant and discharge location
for Renton effluent.
6. The flexibility of a Kenmore plant is recognized in
the section of Chapter 6 of the Final EIS related to growth
impacts resulting from project staging.
7. See General Response Number 4 to PSCOG Letter of January
8, 1981.
8. Metro is undertaking additional work to fully address
these questions. Preliminary results show that for all classes
of users (residential, commercial and industrial) about one-
third of the capital costs of the recommended long-term program
for the Renton system are for existing customers. The re-
maining two-thirds of the capital costs are for facilities
to serve future customers. About 5 percent of the capital
costs are assigned to existing industries and 11 percent
of the capital costs are assigned to future industries.
The operation and maintenance costs are generally pro-
portional to the demand on the treatment plant. Because
new customers are charged the same as existing customers,
overall there will be no subsidy of the increased operation
and maintenance costs due to growth. Similarly, the high
strength and high volume surcharge for industrial users helps
ensure that industrial users pay their fair share of these
costs.
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Municipality of Metropolitan Seattle
Exchange Bldg. • 821 Second Ave., Seattle,Washington 981D4
February 17, 1981
Mr. Roger K. Mochnick
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue, M/S 443
Seattle, Washington 98101
Dear Mr. Mochnick:
Metro staff has reviewed EPA's Draft Environmental Impact
Statement (EIS) on Metro's Draft Wastewater Management
Plan for the Lake Washington/Green River Basins. Through-
out the planning process, both EPA staff and the EIS
consulting team have done an excellent job in coordinating
the preparation of the DEIS with the Draft Wastewater
Management Plan. We appreciate your commitment to this
cooperative approach as well as your success in meeting
deadlines to complete the Draft EIS on schedule. The
Draft EIS, when finalized, will undoubtedly be a helpful
tool for Metro Council decision makers in evaluating the
Metro staff recommended program, the alternatives considered,
and the implication of taking no action.
During this public review period, we have routinely forwarded
numerous technical and editorial corrections/comments to your
staff. We anticipate that the Final EIS will respond to
these items. The only additional comments we have relate to
Chapter 7 of the Draft EIS, "Alternatives Available to EPA."
We ask that you consider the implications of the potential
grant conditions discussed in that chapter. Some of the
grant conditions could be fully implemented under Metro's
existing authority. Others (specifically those related to
"secondary impacts") pose a question as to whether Metro has
the ability or authority for effective implementation. It
is not clear how these types of potential grant conditions
relate to the federal regulations requiring that Metro must
have the necessary legal and institutional resources avail-
able to implement the facilities plan (CFR 35.917.1, Section
h). Perhaps the best way to address these types of potential
Roger K. Mochnick
February 17, 1981
Page two
grant conditions is to identify, in the Final EIS, the
governmental agencies with authority for implementation.
We look forward to your continued cooperation in preparing
the Final Facility Plan and EIS.
Sincerely,
Rodney G. Proctor, Manager
Environmental Planning Division
RGP:khj
cc: Mr. Bob Kievit, EPA
Ms. Rosemary Walrod, DOE
File
(D
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Response to Metro Letter of February 17, 1981
1. Grant conditions have been developed in more detail
in the Final EIS. The proposed grant conditions are con-
sidered by EPA to be within Metro's legal authority.
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CITY OF NORMANDY PARK
240 S.W. 200TH
NORMANDY PARK. WA 98166
TELEPHONE (206| B24-Z602
February 17, 1981
RESOUjTlon ro. -37?
A RESOLUTION OF THE CITY OF NOSJ-IA^DY PAP* AUT.-iGRI Z I:;C THE PKLTAFA: T :'. -:.- -.-'Lt-
OF A LETTER FROM THE CITY MANAGER TO LNVI RCr;XE:JTAL InlTLCT.'C:; A';E:.J?. I-i^::S X,
AND TO THE WETRO COUNCIL, EXPRESSl:,i THE CITY'S FIF.X CPFOSITljN TC ALTL?j:i.7U-E
A-3 OF METRO'S DRAFT KASTEWATER XA.':AJE.'-'iNT FUJI (FiNTON 201 ETLTY).
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Gentlemen,
At its regular meeting on February 12, 1981, the City Council of the
City of Normandy Park adopted a resolution in opposition to the alternatives
proposed for solution to problems revealed in Metro's Wasterwater Mangement
Plan (Renton 201 Study).
We are enclosing that resolution as confirmation of the grave concerns and
firm opposition of the City relative to possible use of south Puget Sound as
receiver of effluent from Renton and other areas east and north of Lake
Washington.
The City of Normandy Park and Southwest Suburban Sewer District are, of
choice, not a part of the Metro system. We acknowledge the outstanding job
done through implementation of that system to address the previous problems
in Lake Washington. However, we fail to see how resolution of the problems
that continue or are projected for areas of Renton and north and east of Lake
Washington should suddenly be imposed on the areas of south Puget Sound at the
expense and adverse impact of its residents and water quality of south Puget
Sound.
We request that this letter and its accompanying resolution be made a part of
the record in opposition to Alternative A-3 of Metro'd Draft Wasterwater
Management Plan (Renton 201 Study) .
Sincerely
at a public meeting with the City Ca-ncil and South-'est Eub'-r=2
Margaret C. Lane
City Manager
FEB 20 1981
ENVIRONMENTS ?
BftANlH
Puget Sound Governmental Conference
Office of Senator Henry Jackson
Office of Senator Slade Gorton
Office of Congressman Mike Lowry
Councilman Paul Harden, Chairman, King County Council
Edward B. Sand, Building & Land Development, King County
City of Tacoma; Pierce County Land Development Department
Normandy :
1, There is no assurance tr.at the long-term c'jnulative eff-;c;s
high volume of effluent discharge wculd not adverasl y affe^T
environment of Puget Scur.d, particularly from the point of -L
proposed discharge southward. Specifically, this ccr.cerr. re
a) Contanination of the shoreline of the City of Ncr~.ar..i/ ?±
veil as that of its Planning Area or "Sphere cf Ir.fluer.-e
Vashon Island.
c) Hater quality of Co.Tjn=r.cemer.t Bay in Taccr.a, which is alre^iy
experiencing severe polluticr to fish life due to ir.c-Jstrial
contamination.
2. T/ie full inpact, bcth ecologically and financiallv, of tu.-.r.cl
construction to the Poi:it Pulley area has obvicuslv r.c- reer. =:ver.
proper consideraticr.. The pre-selecticr. of sites vith:^: er.= ir.2^n
data to determine costs exppses the acer.cies , local aoverrr
J. Our local waters are not currently receiving heavy metal ccr.-2-ir.a:: 3-
howevei-, such contamination would occur ur.der the prcrcsed ?ia,-.. The
also grow and need to address its own grcwth premiers, ir.j".->iir.= EC-
disposal.
5. It is not acceptable to provide for local water Duality s.j-iies "s.:~<
at Pulley Point or at Alki, full flew studies must te ^.a~e cf -he
entire affected Puget Sound basin to determine the lor.g-terr eff*".
such quantities of effluent.
6. There appears to be a conflict of interest in that tue rfc --- tV=
proposed project has been prepared by the EPA. Tnis latter cr = 2-:;=.
is the agency chartered to review and approve an r:s cr. bc.-.ilf cf -'.•
public. How, then can the same agency, workir.g w:ch .''.e-r=. alsj
assume responsibility to provide" objective criticise? ' * '
^'sHin
y
FE3 20 13S!
-------
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF NORMANDY PARK DO RESOLVE AS
FOLLOWS:
RESOLVED: That the City Manager is hereby authorized and directed to prepare
and release a letter to the U.S. Environmental Protection Agency, Region X,
and to the Metro Council, expressing the City's firm opposition to Alternative
A-3 of Metro's Draft Wastewater Management Plan (Renton 201 Study) for the
reasons as specified above.
PASSED BY THE CITY COUNCIL OF THE CITY OF NORMANDY PARK
c^x -"•* j_ 'i-^^-^^ 1981.
, —- --^
City Clerk ./
L/
Response to City of Normandy Park Letter of February 17,
1981
1. The Final Plan recommended program delays a decision
on whether flows from the north part of the study area will
be diverted to the Renton plant.
While Metro's jurisdiction includes all of King County,
Metro's enabling legislation allows Metro to provide service
outside King County by contract with local agencies. There
are local sewerage agencies within King County which are
not part of the Metro system, e.g., Vashon Island, south-
western King County, and cities in the Snoqualmie Valley.
The Metro facility planning area includes those areas
within the Lake Washington and Cedar/Green River basins which
are physically tributary to Metro treatment plants. The
Renton study area is that eastern portion of the planning
area designated in Metro's comprehensive sewerage plan which
could flow to the Renton treatment plant for treatment and
disposal.
If diversion to Puget Sound is a part of a final facilities
plan, approved by EPA and the Washington DOE, Metro could
then design and construct the tunnel and outfall to Puget
Sound even if the tunnel/outfall were located in an area
not served by Metro. Metro would, of course, have to secure
the appropriate easements and permits regardless of the route
selected.
2. See General Response Number 2.
3. See General Response Numbers 7, 11, and 15.
4. Heavy metals occur in virtually all portions of central
Puget Sound from a variety of point and nonpoint sources.
Metro is presently conducting a study of sources, fates,
and control measures for toxic substances, including metals,
for all Metro wastewater treatment plants.
5. There is no obvious relationship between selection of
a wastewater management plan for the Renton study area and
meeting the sewerage needs of the Normandy Park area. If
the assumption is that Puget Sound has a highly limited
assimilative capacity for wastewater that future discharges
from the Normandy Park area would completely utilize, there
is no evidence to support this idea.
6. See General Response Number 15.
7. See General Response Number 13.
-------
I..
Charles M. McGill, H.O., H.P.H., Acting Director of Health
(DJ
February 20, 1931
rE8
ENVIRONMENTS EVrJj.iI
BfiWiCH
Roger Kochnick
E.P.A. Recion X
1200 Sixth />ve"'je
Nai 1 Stop 443
Seattle, Washington 98101
RE: Metro Wastewater Management Draft E.I.S.
Dear Mr. Hochnick:
The Tacoma-Pierce County Health Department would like to take this opportunity
to express its general concern about water quality impacts upon the Tacoma area
by the proposed sewage outfall at Point Pulley in King County.
A brief review of the literature available coupled with discussions with several
state agency erployees indicates that up to 90S of the treated effluent would
rove southward into this area of Puget Sound. The Tacocia-Pierce County Health
Departnent wishes to go on record with the recommendation that the discharge of
effluent be located where flushing would rapidly discharge the sewage out of the
Sound.
Sincerely,
0 '
5) nc
Q
Charles M. McGill, M.D., H.P.H.
Acting Director
nike Parker, Chairman, Board of Health
Jack 6ujac:c1, Vice-Chainr.an, Board of Health
Joe Stortini, ."ember, Board of Health
Jack Hyde, Berber, Board of Health
William Chunyk, Member, Board pf Health
;-:ET?.0
TACOMA-PIERCE COUNTY HEALTH DEPARTMENT
Response to Tacoma-Pierce County Health Department Letter
of February 20, 1981
1. See General Response Number 1.
3629 SOUTH D ST. TACOMA, WASHINGTON 98408
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Your City, Seattle
EVALUATION
-------
Response to City of Seattle Letter of February 23, 1981
1. The final plan recommended program has deferred the
decision on diversion of flows from the north part of the
study area to the Renton plant. The additional matters dis-
cussed will be addressed in the Final Plan and EIS for Metro's
Puget Sound plants.
^. See General Response Number 3.
3. The Final EIS points out that the nitrification process
can be difficult to initiate and maintain. An analysis of
the effects of nitrification process upset has been added
to the Final EIS.
4. Metro's final plan recommended program has deferred
the decision on construction of the Redmond and North Creek/
Hollywood connections.
5. See General Response Number 3.
6. See General Response Numbers 2 and 9.
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THE RENTON CITY COUNCIL
g MUNICIPAL BUILDING • 200 HILL AVENUE SOUTH • R£NTON, WASHINGTON 9*055 • 23S-2S86
Response to City of Renton Letter of February 18, 1981
1. The solids processing facilities at the Renton plant
will be operated in such a way as to minimize odor impacts.
As to ultimate solids disposal, see General Response Number 5.
2. See General Response Number 12.
Mr. Jeff Bauman
Municipality of Metropolitan Seattle
Exchange Building
821 Second Avenue
Seattle, UA 98104
ortANCH
Dear Mr. Bauman:
Subject: Renton 201 Facilities Plan
Pursuant to our discussion on February 5 with Mr. John Lesniak of Metro
concerning the Renton 201 Study, we offer the following comnents on the
Draft Plan. We are concerned about the treatment of solids at the Renton
Treatment Plant. Any significant stockpiling of solids or emission of
objectionable odors would be unacceptable impacts and should be addressed
in the Final Plan. Likewise, the ultimate disposal of processed solids
must be examined.
We are also concerned that the real proportion of additional facilities
costs attributable to commercial and industrial development be charged
to these users rather than to residential users. The Final Plan should
include a breakdown of anticipated service charges for various types of
users.
Thank you for the opportunity to review this Draft Plan.
any questions, please contact this office.
Si nee rely ,
Should you have
Richard M. Stredicke
President, Renton City Council
GW:bd
cc: Roger K. Mochnick, EPA^
(D
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ORGANIZATIONS
376
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CITIZENS COMMITTEE FOR CLEAN WATER
107 SOUTH MAIN, SEATTLE, WA. 98104 / 623-1483
January 21, 1981
Kr. Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
This letter contains the comments of the Citizens Committee for Clean
Water on METRO'S Wastewater Management Plan for the Lake Washington/Green River
Basins. It is based on data in EPA'S (Region 10) Draft Environmental Impact
Statement and in METRO'S Draft Plan Summary of its Wastewater Management Study
for Lake Washington/Green River Basins (Renton 201 Study). Both documents are
dated December 1980.
We concur in expansion of the existing Renton secondary treatment
plant and with the discharge of its effluent through a forced main, tunnel and
new outfall in Puget Sound off Alki Point. This plan has been designated A-5
and is essentially identical with the Renton portion of METRO'S Preferred Facility
Plan (PFP). The latter plan was recommended by METRO'S Executive Director,
Mr. Neil Peterson, to the. KETRO Council on August 17, 1978. For this reason Plan
A-5 is capable of being integrated into METRO'S planning for the Duwamish treat-
ment plant and therefore would be able to share in the cost of the needed new deep|
water outfall in Puget Sound. Plan A-3 does not have this capability and would
require a separate outfall for the Duwamish plant, thus inordinately increasing
the cost of an urgently required facility to process our industrial wastes.
We would also welcome the decentralization inherent in Plan B-l, which
assigns 25% of the Renton service area to a new plant in the kenmore area.
Centralization of sewage treatment plants can precipitate major environmental
disasters when plant failures occur— and unfortunately failures can and do occur.
We do not concur with that portion of Plan B-l that calls for discharging
treated wastewater into the Duwamish River. This important anadromous fish
producing river already carries too many pollutants for the continual preservation
of its salmon resources.
We also are opposed to its obvious lack of coordination or integration
with METRO'S planning for a Duwamish treatment facility.
We are concerned that the cost of the Phase 1 expansion of the Renton
plant has increased well beyond the recorded inflation rate for construction and
justifies a review by our elected officials, beyond what is possible at workshops
and public hearings.
contd.
Mr. Roger K. Mochnick
January 21, 1981
Page 2
Following is a summary of METRO'S old and new cost figuresi
METRO'S PFP METRO'S Plan A-5 %
August 1978 Dec. 1980
(millions) (millions)
Change
Renton Phase 1
Expansion
Force Main, Tunnel
Alki Outfall
Standard
Engineering News-Record
Construction Cost Index
(C.C.I.)
$34.3 M
83.5 X
3000
$74.8 M
240.3 M
3500
188*
That portion of the EIS concerned with the growth-related impacts of
the alternatives has not addressed cost-sharing among METRO rate payers. As we
understand current procedures, the costs of METRO'S Wastewater Management Plan
for Lake Washington/Green River Basins will be allocated equally to all current
and future rate payers. This will be done regardless of where rate-payers live
and regardless of the extent to which they have already aaoritized the cost of
the facilities they have been and are using. What needs to be addressed in the
EIS to facilitate its use as a decision document are the growth consequences of
- requiring growth areas to pay all, or at least a larger proportion of, the costs
associated with handleing their sewage.
We do not assume to know where equity lies in this matter and we expect
that it will be resolved, as it should be, in an appropriate political arena.
But we do know that the citizens of Seattle and its northern ar.d southern sutures
will have to assume a substantial burden just in upgrading their own treatment
facilities— with or without the participation of rate payers in the flenton
service area. An addition to this burden of a rate increase that is essentially
a subsidy to the development of east-side open spaces appears to be an impact that
should be displayed in the EIS, discussed at the workshops and addressed at the
public hearings.
There are approximately 65,000 house holds in the Renton service area,
presently on septic tanks. They have contributed nothing for costly water quality
but receive the benefits from METRO'S programs. They could be accused of contrib-
uting to the degradation of water quality.
We recognize that an approach to equity could be achieved if METRO' s
Plan provided improvements to water quality in Puget Sound opposite the City of
Seattle and its northern and southern suburbs. IT DOES NOT.
METRO'S request for a waiver from secondary treatment for its Puget
Sound plants, means that the noxious character of 80,000 Ibs of suspended sewage
solids will continue to be discharged into Puget Sound every 24 hours. If granted
this discharge could be continued for another five years and renewed at the end of
that tine. Source control of both heavy metals and toxicants has not yet been
initiated and in any case will have little effect on donestic sources.
contd .
DEDICATED TO THE IMPROVEMENT OF WATER QUALITY AND
BETTER MANAGEMENT FOR WATER RESOURCES
-------
Mr. Roger K. Mochnick
January 21, 1981
Page 3
Our final concern relates to the cost consequences of the time already
used by METRO in planning and studies. The current phase of METRO'S planning
began in 1970 with the RIBCO effort. A METRO report was published in December
1971* as part of this study (Part III, Water Quality) and recommended expansion
of the Renton plant and upgrading to secondary treatment of KETRO's plants at
West Point, Carkeek, Richmond Beach and Alki, all at a 1973 cost of $159,050,000.
Including second phase expansion costs to 1990. See pages 116 and 117 from
The Construction Cost Index - 1763, 1973 Engineering Kens Record; plant capacity
of the system was Wj.5 mgd.
In August 1978 the Construction Cost Index had increased 70% to 3000.
However, METRO' s estimated cost for its August 17, 1978 Preferred Facility Plan
with 100^ secondary treatment had Increased by
to $514,000,000. Plant capaci
was 222 mgd inclusive of i new plant at Duwamish that would phase out Alki.
Twenty-eight
ight months later, the Renton portion, (Plan A-5) of the August
ility Plan had increased from $117,800,000. to $315,000,000.—U]
is regarded in many quarters as disastrous. What can rate payers expect
when the needed work actually is advertised for bids?
We ask most sincerely; Is METRO taking the tax payers of King County
down the same path as the Washington Public Power Supply System?
Ten years of planning has taken place without METRO having upgraded any
of its treatment plant discharges into the Duwamish River or Puget Sound, but with
astronomical increases in the estimated construction cost of mandated facilities.
Under these circumstances we suggest EPA cease financing METRO'S planning efforts
and direct immediate action to achieve early compliance with Federal Law and METRO'E
own enabling legislation. From the results to date, additional planning can only
result in cost increases well in excess of current inflation with the distinct
possibility of the needed and required sewer system costing more then the taxpayers
can afford.
However, we recognize that the 10-year planning effort, coupled with
the public involvement financed largely by EPA, has told us what needs to be built,
and where. Reasonable alternatives have been proposed that employ METRO'S pre-
ferred facility configuration and which defer upgrading to 100^ secondary for
another 30 to 35 years. We made such a recommendation two and one half years ago.
Let's get on with the job while it is still possible to pay for it and also improve
water quality in Puget Sound.
Thos. 0. Wimner,
Citizens Committee for Clean Water
C.C. Mayor Charles Royer
Governor John Spellman
Seattle City Council
Kin» County Council
Mr.'Donald P. Dubois, EPA
Mr. John Spencer, DOE
Response to Citizens Committee for Clean Water Letter
of January 21, 1981
1. See General Response Number 9. Also, see Response Number
7 to PSCOG letter of February 5, 1981.
2. The Final EIS recognizes the flexibility provided by
Alternative B-l, and the construction of a Kenmore plant is not
precluded by the final plan recommended program.
3. No response required.
4. Metro believes the cost estimates presented in the final
plan are generally accurate plus or minus 20 percent.
5. It might be assumed that charges to new residents in
the Metro service area would increase if they bore the full
cost of expansions of the core treatment system. However,
it is impossible to determine what, if any, impacts this
might have on land use patterns in the service area.
6. In a sense, on-site users already help pay to protect
water quality. They pay federal taxes which support Metro's
facility planning and 208 functions through the Clean Water
Act grant program. As state residents, they also contribute
to the Referendum 39 grant program. Whenever on-site users
have their septic tanks pumped, part of the charge covers
the cost of treating the septage at the RTF. It should also
be noted that the cost of installing and maintaining a septic
tank system is borne by the local user. In these ways on-
site users are paying to protect public health and water
quality.
7. The cost differences result from elements of the plant
expansion and Alki force main, tunnel and outfall that were
not part of the 1978 Puget Sound Facilities Plan. Specifically,
Renton plant expansion from 36 MGD to 72 MGD was estimated
in 1978 as ?53.8 million, not $34.3 million ($34.3 million
was expansion from 48 to 72 MGD). A CCI increase from 3,000
to 3,500 increases this to $62.8 million. The Renton Facility
Plan includes a plant expansion cost of $74.8 million. The
$12 million increase over $62.8 million results mainly from
sludge processing facilities not considered in the earlier
plan. The Alki outfall was estimated in 1978 to cost $83.5
million, increasing with the CCI to $97.4 million. The $240.3
million cost estimate for the Alki outfall in the Renton
plan results from the need for pump stations and force mains
rather than gravity flow, and the need for a 144-inch diameter
rather 120-inch diameter pipe, deeper trenching, trench sheet
-------
piling construction, stabilization and well point dewaterinq.
These identified needs resulted from detailed analysis in
the Renton plan, including hydraulic profile, soils review,
utility conflicts and groundwater levels.
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CITIZENS FOR CLEAN WATER
107 SOUTH MAIN, SEATTLE, WA. 98104 / 623-1483
February 16, 1981
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
The enclosed comments reflect some of the areas of
concern by the Citizen's Committee for Clean Water of the
DEIS for the Wastewater Management Plan for the Lake
Washington/Green River Basis (Renton DEIS). We have stated
our position on this issue at one of the public hearings.
We have repeatedly voiced our concern for the inadequate
public involvement of this and previous plans. It now appears
that another alternative, called A31, is being considered.
This new plan is not merely a slight modification of A3, but
an attempt to make the price tag more palatable by delaying
needed facilities for the next generation. We would expect
the A31 plan to be discussed in public hearings before it is
included in the final EIS.
Metro's role in water quality management is not totally
clear. On the one hand, Metro claims to provide only a
"wholesale" sewage treatment service. On the other, Metro is
actively engaged in water quality activities, such as milfoil
removal and fish enhancement. If Metro is, in fact, a
super-sewer district then they should let another agency
manage water quality. If Metro is the water quality manager
for the Seattle area, then the cost of sewage treatment
should not influence water quality decisions. This conflict
in roles is not in the public interest.
(D
RENTON DEIS COMMENTS:
If the existing Renton treatment plant is expanded to 99 MGD, when will the
expected population growth require the next phase of expansion? What will happen
when the Renton site reaches its 144 MGD limit and further expansion is
necessary?
Of the 40 component agencies in the Renton study area, what is the sewered and
non-sewered population within each agencies boundries?
How does EPA determine if a proposed project is "innovative and alternative' to
receive 85% federal, funding? Which, if any, of the proposed alternatives would so
qualify? How would this additional federal funding affect the estimated sewer
charges?
It appears from the projected monthly sewer charges (table 3-3) that many of the
alternatives differ by only a few pennies. At what relative rate will monthly
costs of each of the 15 alternat ives likely increase with time? Is it possible
for a low sewer charge alternative to be more expensive in the long-term? What
would happen to the sewer charge if only the residents of the Renton service area
paid for that plant's expansion?
"Metro considers
area to be infeasibl
O- 7/ATSKCUAUTY -NO
the purchase of...(5000 acres)...within a growing metropolitan
area no oe inteasible." Is this a Metro staff decision or a policy of the Metro
Council? What would be the cost of such land aquisition? What type of treatment
would such effluent receive prior to entering the lagoon? What type of land would
be required for spray irrigation and storage lagoons?
What types of satellite pretreatment has been considered, and what are the range
of costs? Has any form of "in-pipe" treatment been considered?
In the "no-project" alternative, at what point would a sewer moratorium be
imposed? Which agency has the authority to impose such a moratorium? If the
Renton treatment plant is currently operating in a "stressed mode", and it will
be several years before any capacity expansion project is completed, why is not a
moratorium already in existence? When did Metro first predict reaching plant
capacity at the Renton treatment plant? Why is this pianning process taking place
AFTER the plant reached the stressed mode? How much is the daily fine for
violation of the discharge permit?
Table 3-5 implies no negative impact on fisheries/shellfish protection from any
of the alternatives. Does this mean that shellfish on Seattle beaches will no
longer be contaminated? What Puget Sound plans are being used to establish
compatibility with each alternative? What weighting factors were assigned to the
various criteria?
How much of the methane gas is expected to be utilized at the plant? How much
less methane will be produced at West Point as a result of local sludge digestion
at Renton? What will happen to any excess methane? Is there a cost savings in
trucking sludge from Renton as opposed to West Point?
How do the costs of these alternatives compare with those predicted in the
Preferred Facilities Plan and other planning efforts, including the RIBCO
Studies? What are the reasons for differences? How much has been spent on 201/208
related studies by Metro since 1972?
Table 3-10 compares the costs of sludge disposal systems. What benefits might be
returned to local and state taxpayers from each of the options?
(5)
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Response to Citizens Committee for Clean Water Letter
of February 16, 1981
1. The A-3 alternative is identical to the program recom-
mended in Metro's final plan. This alternative is evaluated
extensively in the Final EIS, and it will be the subject
of additional hearings.
2. Metro's enabling legislation gives Metro the responsi-
bility for water pollution abatement functions. Metro believes
its sewage treatment and areawide water quality responsibilities
are fully consistent with Metro's mandated function. Metro
bases this on DOE's designation of Metro as the areawide
water quality agency (208) for the Cedar/Green River Basins.
3. The Renton facility plan has a 20-year horizon. Beyond
that point in time additional planning will be necessary
to define exactly what long-range configuration would be
most cost effective. At this time, it appears that, based
on a 50-year horizon, a Kenmore treatment plant might be
cost effective near the end of the 50-year planning horizon.
4. The population projections utilized for the Renton study
were prepared by PSCOG and are disaggregated by subdrainage
basin or AAM district. To provide sewered and unsewered
estimates of population by component agency would require
additional work by PSCOG.
5. EPA determines qualification of facilities as "innovative
or alternative" on the basis of reclamation and reuse of
water, recycling, energy recovery, and other such achievement
of benefits. Metro has proposed several project components
that may qualify, such as certain sludge handling and disposal
facilities, heat recovery facilities, and septage handling
facilities. If specific projects qualify for 75 percent
federal funding and also qualify as innovative or alternative,
an additional 10 percent funding is available. This would
reduce the necessary local share and resulting increases
in sewer charges.
6. The present worth analysis allows an equal comparison
of alternatives with different staging and phasing schedules.
However, the impact of inflation also affects the cost of
the various alternatives, which in turn affects the monthly
sewer rates. Rather than analyzing the impact of inflation
on the monthly sewer rates, Metro analyzed the impact of
inflation on the present worth of each of the alternatives.
Monthly costs for alternatives with increased treatment,
and thus higher O&M costs, rise faster over time than monthly
costs for tunnel alternatives. The final plan displays in
Figure 3-12 (page 83) the impact of inflation on the monthly
rates for the recommended program.
It is possible for a low sewer charge alternative to
be more expensive in the long run; that is why present worth
and inflation analyses were prepared.
Also, see General Responses Numbers 10 and 12, and Response
Number 8 to City of Bellevue letter.
7. Spray irrigation is a land application system that utilizes
evapotranspiration as the primary means of wastewater disposal.
The type of land best suited for spray irrigation is generally
flat with soils of slow to moderate permeability. Soils
with rapid permeability are not desirable. Soils with extremely
slow permeability, soils which are seasonally saturated with
groundwater, and soils with groundwater too near the surface
are also undesirable for spray irrigation.
Prior to storage in lagoons, wastewater would go through
a screening and grit removal process and would then be treated
in an aerated lagoon and facultative lagoon. The effluent
would then be disinfected with chlorine prior to storage
or irrigation.
As to decision-making responsibility, the ultimate decision
regarding a land application system will be made by the Metro
Council.
8. Satellite pretreatment was considered in Metro's pre-
liminary plan (pages 54-55. It was screened from further
consideration because most areas suitable for satellite pre-
treatment are already connected to the Renton system.
Assuming "in-pipe" treatment refers to aeration of
effluent in the interceptors tributary to the RTF, such a
system has also been discussed during the course of the study,
but was not pursued in greater detail because it would not
offer a solution to either the capacity or ammonia concerns
at the Renton treatment plant. In-pipe aeration is often
used to solve hydrogren sulfide odor and corrosion problems.
It does not offer an alternative to either advanced wastewater
treatment or diversion to Puget Sound.
-------
9. A sewer moratorium has been considered by Metro as one
of more than a dozen interim measures which could be imple-
mented to protect water quality during the interim period
while design and construction of the Renton treatment plant
expansion is underway. It should be noted that a sewer mora-
torium does not represent an alternative to expansion of
the treatment plant and diversion to Puget Sound.
Metro could, if necessary, temporarily refuse to con-
struct any Metro facilities to serve new areas. However,
Metro does not have the authority to prohibit the issuance
of building permits or sewer hookups. Action by the Department
of Ecology, EPA, and/or local governments would be necessary
to impose a moratorium on local sewer hookups. Even if enacted,
experience in areas which have imposed moratoriums indicates
that such actions may not be effective in slowing increased
flows.
In any case, Metro is confident that a moratorium need
not be considered. There are other, more effective measures
which will be implemented to protect water quality during
the interim period.
As to initiation of the planning process, it was not
until 1979 that Metro received a grant through the 201 Con-
struction Grants program to prepare a facilities plan. Although
Metro had requested funding earlier, there was not enough
money to njeet all the planning needs in the state. Although
flows to the RTF do exceed design capacity, Metro has initiated
interim measures which are designed to protect water quality
while design and construction take place (see Final Plan,
pages 84-90).
As to fines for violation of NPDES permits, the Washington
DOE staff have indicated that a maximum of $5,000/day may
be imposed.
10. Although shellfish contamination from a Renton outfall
to Puget Sound is not expected, shellfish are still impacted
by other sources including urban runoff. Compatibility with
previous Puget Sound planning was considered in terms of
cost-sharing with the proposed Duwamish plant and with CSOs.
As to weighting factors for the evaluation criteria,
the criteri.i in Table 3-5 are not weighted. The purpose of
the table was to help identify possibly overriding considera-
tions compared to the least-cost alternative, A-l, which
was then discussed in the text. The table was not intended
to statistically rate the alternatives against the criteria
nor to numerically rank the alternatives.
11. Construction of solids processing on-site at Renton
will mean discontinuance of transfer to the West Point plant.
During the first 11 months of 1980, solids discharged from
the Renton plant were equivalent to 31 percent (81,000 Ib/day)
of the influent solids load at the West Point plant. Removing
these solids will reduce gas production by an estimated 388,000
cubic feet per day, assuming primary solids capture of 60
percent, volatile content of 74 percent, 60 percent destruction
of volatile solids in digestion, and 18 cubic feet of gas
production per pound of volatiles destroyed. If Renton solids
are captured less efficiently than other raw sewage solids
and are more difficult to digest because of the waste activated
component, the impact on West Point gas production will be
less severe.
Production of gas in Renton solids handling facilities
is estimated to increase from 388,000 to 2,250,000 cubic
feet per day for the year 1980 and 2000 loads, respectively.
This is based on current solids projections, 60 percent capturu
of primary solids with 76 percent volatile content, 70 percent
carryover of BOD to the secondary system, conversion of 0.65
pounds of BOD to pounds of suspended solids, waste-activated
sludge volatile content of 78 percent, 60 percent destruction
of volatile solids in digestion, and 18 cubic feet of gas
produced per pound of volatile solids destroyed. The solids
system proposed for the Renton plant would produce more energy
than required to sustain the digestion process under normal
operating conditions. The excess gas would be used to drive
engines for pumps and blowers, or generators for electric
production, to reduce the energy demand of the rest of the
plant. Energy recovery from solids processing would not
produce enough energy to supply all of the plant's demand.
As to cost savings associated with trucking the sludge,
it is likely that there will be some cost advantage associated
with transporting sludge from the Renton site. Generally,
Renton is closer to many potential sludge utilization/disposal
sites. Of course, the amount of the savings will depend
on the ultimate site(s) selected. Decisions about ultimate
disposal sites will be made as part of Metro's long-range
sludge management study currently in progress.
12. See Response Number 7 to Citizens Committee for Clean
Water letter of January 21, 1981.
13. From 1972 through mid-1981, Metro spent approximately
$3,440,000 on facility planning for the Puget Sound treatment
plants (West Point, Alki Point, Carkeek Park, and Richmond
-------
Beach) and the Renton treatment plant. An additional $1,100,000
was spent on the Puget Sound interim studies and $1,816,000
was spent doing pilot plant work. While the interim studies
and pilot plant work may not be considered facility planning
per se, they were directly related to the facility planning
and are included above for that reason. It should be noted
that the total costs identified above include local costs
as well as costs reimbursed by state and federal grants.
14. Based on preliminary conclusions reached in Metro's
sludge management study, silviculture, soil improvement,
and composting have been identified as the most promising
utilization/disposal alternatives. These alternatives are
currently being analyzed in greater detail. Composting offers
the potential for marketing Metro sludge on a limited basis
for restricted use (according to EPA's proposed draft of
regulations pertaining to the marketing and distribution
of sludge products). Metro sludge has also been used by
Groco, Inc., to prepare a compost material which has enjoyed
a modest marketing success. Metro's long-range sludge manage-
oo ment plan will address the role that composting will play
u in Metro's sludge program.
-------
Magnolia
Community
Club__
P.O. BOX 99164 • SEATTLE. WASHINGTON 98199
February 9, 1981
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
The Magnolia Community Club has examined the Wastewater
Management Plan for the Lake Washington/Green River Basins draft
EIS. The Club has commented on previous documents and has long
supported efforts to improve water quality. These efforts have
included adoption of criteria to be considered for site select-
ion and construction of treatment plants.
Response to Magnolia Community Club Letter of February 9, 1981
1. See General Response Number 12. As to costs borne by
on-site system users, see Response Number 6 to Citizens
Committee for Clean Water letter of January 21, 1981.
On Feburary 5, 1981, the Club's Board of Trustees voted to
request that Metro investigate equality of the existing sewer
charge and alternatives thereto. In view of proposed and pros-
pective Renton treatment plant expansion, it appears the exist-
ing sewer charge places an unfair burden on Seattle residents
and does not place enough responsibility for growth management
on the governmental agencies in the Renton service area. It also
appears that 65,000 septic tank households are enjoying the
benefits of Metro improved water quality, but are not sharing in
the cost of these improvements.
The Magnolia Community Club recommends that this subject be
discussed in the Final EIS.
Sincerely y'ours,
Janet Anderson
President
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MUCKLJESHOOT INDIAN TRSBE
FISHERIES DEPARTMENT
39O15 172ND AVENUE S.E. - AUBURN, WASHINGTON 98002 - [SOB] 939-3311
Response to Muckleshoot Indian Tribe Letter of February 10,
1981
1. EPA agrees with this observation. The final plan recom-
mended program calls for diversion of Renton effluent to
Puget Sound to protect the Green/Duwamish River fishery.
2. Once the outfall to Puget Sound is built, it would not
be possible for a plant failure to adversely affect the Green/
Duwamish River.
fe.bfiu.atiy TO, 7987
MJI. Rcge* K. Uochnink M/5 443
Enu.i.tonmenta.C Evaluation Branch
U.S. Enui/ionmentai PtLOte.c.tion Agency
7200 Sixth Auenue
Seattle, (Ha 9S707
Peal Mi. Mocnn-icfe,
In iev.iew.ing tfee dtiafat Plan AummatLy and E.P.A.'i
Impact State.me.nt on UittLo'A WaAte.aate.tL Management Plan
ton/Gmn Rive.1 BaAinA, we wou£d like, to Au-bmit the.
Environmental
Lake. UaAhing-
comme.ntA :
The. Mu.c.kle.Ahoot Indian TtLibe., Met^o and vatLiouA ApotLtA and tLe.c.tLe.ation-
al oiLaanizationA, have, a ve.Ate.d inte.tLe.At in the. uiatitL quality of, the. GAeen
VuuamiAh Rive.tL. biate.1 quality haA du)indle.d to dange.tLOUAty low te.ve.lA in
the. tLive.tL dutLing the. Au.mme.tL loa ^louiA uihe.tLe.aA the. e^iuent (,tLom the. Renton
treatment plant haA c.omptLiAe.d aA much aA 251 ofi the. total iLive.n. (,low.
The. 4 alte.x.native.A de.Ac.tLibe.d in the. E.I.S., A-7, A-3, A-5 and B-7,
only two o (, the. alte.tLnative.A could ^ully e.liminate. uiatitL quality c.onc.e.iLnA
in the. GtLe.e.n/VuujamiAh Rive.tL. f.lte.tinative.A A-7 and 8-7 wou£d provide. Aome.
admoniAhmtnt to the. wate.tL quality ptLoble.mA, but the.y do not Ao.tve. the.
te.mpe.iLatu.tLe. ptLobltm. Vive.tLAion o{ the. e.{,^lue.nt fatLom the. tiivitL to Puget
Sound via pipe.line. to Alki Point OIL faint Pully AiimA to be. the only p/iac
tidal alte.tLnative.A ,
ptLote.c.tion of, the. aquatic. iLtAoutLtiA ptLOvide.d in t
Vu.uiamiAh/GtLe.e.n Rive.tL, the. Aa.tmo_n and Ate.ithe.ad tie.Aoutic.e.A biing among the.
latLQiAt in the. Pu.ge.t Sound tLigion. MAO a concern which muAt be. addtLe.AAe.d
iA a c.e.nttLalize.d ttLe.atme.nt Ac.he.me. nan ptLe.c.ipito.te. an adve.fiAe. impact upon
the. VuuiamiAh Rive.tL, Ahould the. plant have, a majotL (^ailutLe.. Ptie-caiLtionatL
me.aAun.e.A muAt be. imple.me.nttd to inAuae. minimal impact upon the. tie.AoutLC.e.A ,
thank you 1(0/1 the. opportunity to commtnt.
Sinctti
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West Seattle
CHAMBER OF COMMERCE
4210 S. W. Oregon
NORMAN A BEERS
Executive Secretary
Home Phone 932-5409
• Seattle, Washington 98116
937-5550
February 13, 1981
Response to Hest Seattle Chamber of Commerce Letter of
February 13, 1981
1. The trade-offs between Alki Point and Three Tree Point
as discharge locations, such as those indicated by this letter,
were evaluated in both the Final Wastewater Management Plan
and Final EIS.
Environmental Protection Agency
Region X
1200 - 6th Avenue
Seattle, WA 98101
Attention: Mr. Craig Partridge
Gentlemen:
West Seattle Chamber of Commerce is most interested in Metro's Wastewater Management Study.
A special committee of the West Seattle Chamber of Commerce recently participated in the Metro
Hearing, January 6, at Alki Community Church, under the chairmanship of R.R. Greive. The
four Renton 201 Alternatives were presented and discussed. The West Seattle Committee report
was made by Ralph Lyall to the West Seattle Chamber of Commerce meeting Monday, January
11th followed by discussion comprising of the Board of Directors and participating members.
From the evaluation of these alternatives, the West Seattle Chamber favors the Point Pulley
concept for the following reasons:
1. Cost - Economics, at least $78 Million
2. Shortest distance from Renton is direct line to Pofnt Pulley
3. Least impairment to properties through construction - Community destruction and
traffic problems would be greatly accelerated in the Alki Community and along the
entire Duwamish from the Renton plant.
4. Puget Sound Water quality of Point Pulley and Alki comparable with minimal effect.
5. Of significant importance: Alki Community is a highly developed residential area. It's
quality of life would be impaired through disruption of streets and hazardous traffic
problems during the construction process. x
Therefore, because of the reasons listed above, very careful consideration would be given to the
alternate siting of the tunnel rather than at Alki Point or to Alternates A-1 or B-1. Both of
these alternates would mitigate the impact to any given community.
Norman- A. Beers
Executive Secretary
17 iggi
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-2-
February 14, 1981
3773 S.W. 171st
Seattle, Wa. 98166
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Wa. 98101
Attn: Mr. Roger K. Mochnlck M/S 433
Re: Response to Environmental Impact Statement, Lake Washington/
Green River Basins.
Dear Mr. Mochnick:
We are a committee of interested citizens, mainly property
owners in the Seahurst / Three tree Point area which lies within
a planning area (see Figure 1) which we will call the Puget Sound
East Passage or East Passage for the sake of clarity and convenience
of reference in thisletter. We are concerned over the impact
of Metro's proposal to divert Renton Treatment Plant effluent
through a tunnel outfall to an area outside the Metro service area.
This area is defined in the Metro 201 plan as alternative A-3-
Point Pulley. We recognize that this 201 plan is part of Metro's
long range planning process and that the presentation of the various
alternatives is consistent with their authority and responsibility
as a geographically oriented planner and manager of water quality.
The purpose of this letter is to respond to the draft
EIS, 201 plan and to point out to EPA deficiencies in the basic
assumptions, the environmental impact statement, the cost-effectiveness
considerations, and administrative, procedures being followed in their
review. We will also propose some alternatives to the proposal.
I Procedure Concerns
Our concerns over the procedures being followed fall
into the three categories of Federal, State, and Local govern-
mental actions that must preceed any major development.
Questions on Federal Procedures:
A copy of the Environmental Checklist for the East
Passage has not been provided. Has it been completed? If so,
when can we review the data? What will be the impact on the 201
plan or any alternate plan selected by the Metro Council if you
conclude a negative environmental impact would occur as a result
of the proposed development?
There is no indication a request for an NPDES permit
for a "New Source" has been prepared as required by 40 CFR part
124.9 regulations. In addition, part 122.3 indicates a need to
determine continuous discharges for all dischargers and set
average weekly and monthly discharge limitations for Publically
Owned Treatment Works. When do you expect completion of this
requirement?
The requirement for a Public Hearing (part 124.12)
when there is a significant degree of public interest has not
been met. Please note that the published versions of the Plan
and EIS summaries did not even include Public Workshops in the
area affected by the plan alternatives. The Burien workshops
were eventually held only after specific requests were made by
the community.
Is there a draft general permit to Metro for point
sources other than storm sewers as required by part 124.58?
What effect does EPA assumption of lead agency status
for the 201 Draft Plan and Environmental Impact Statement have
on its ability to consider objectively all the issues raised
before it in the review processes?
Questions on State Procedures
The EPA/State Agreement on Water Quality Management
for FY1980, page 79, calls for field samplings of the Duwamish
River. John Lampe ' s Letter * to DOE calls for the State and
Metro to "coordinate their methodologies in order to correlate
the results of the field sample project". What checks and
balances exist to protect the interests and needs of those not
included in Metro's planning sphere, in view of Mr. Lampe ' s
other requests and recommendations in the same letter for an
increased priority for Metro's geographical planning process
and request for area-wide planning powers?
It is unclear to us just what the impact of the joint
hearings on the Draft 201 plan and Draft EIS will be.
More specifically, who is responsible for the review
and approval of the 201 plan, and specifically what criteria,
questions and checklist is used for the acceptance? Similarily
who is responsible for the EIS approval? Is it the same Agency
and Department of that Agency? If either the EIS or the 201
plan is rejected, what is the impact on Metro's total program
as proposed?
Questions on Local Government Procedures
When do you contemplate King County doing a 201 Plan
for the East Passage area? We understand that several members
of the Metro Water Quality Committee did not realize that the
East Passage was not part of Metro's service area, was not
within its planning scope, and that substantial outfall from
Sewer Districts serving this area already exist.
What are the implications of King County's General
Sewerage plan on the alternative selection process? Even though
King County has delegated to the Metro Council (Section 2.5
4)
lancer, '
John
-------
-3-
-4-
of the
doesn ' t
outside
it's Se
therein
is used
decis10
to prov
plan) the authority to select its own receiving waters,
the fact that the preferred alternative is located
of Metro's planning area require the County to amend
werage Plan in accordance with the procedures outlined
before the Metro decision becomes effective? This plan
Sy~aTT planning agencies and Review Boards in making
ms on service areas and capacity of special districts
ide service and the cost of service.
What are the implications to the citizens of the
East Passage with respect to due process and equal treatment
under EPA and SEPA Guidelines and WAC regulations? Neither
the title nor the Metro process in conducting the 201 study
ever related to this area. While we understand the need to
find solutions to the pollution discharge problems confronting
Metro, we find no factor built into the "Trigger Mechanism"
outlined in the Draft Plan that recognizes the planning re-
quirements of the East Passage area and the need to bring King
County into the planning process to determine the effects of
Metro policy decisions on an area outside the Metro planning
area—East Passage.
The East Passage area is approximately the area of
the City of Seattle and has a population of about 200,000
people. According to the General Development Guide of King
County, it can be expected to attain a total population near
that of Seattle by the year 1990. It has been designated as
an infill area in the King County General Comprehensive Plan.
It contains two small cities, Normandy Park and Des Moines
and two very large unincorporated areas, Burien and Federal
Way. We believe the Draft--201 plan and EIS do not adequately
address the long-range planning requirements of this area.
II Environmental Concerns
Impact of Redmond Connection
We do not believe it is logical and in compliance
with the intent of the Clean Water Act to divert a large quantity
of polluting effluents from the far north drainage area of
King County way south to the East Passage area in order to
introduce it into a much more ecologically fragile portion of
Puget Sound.
Impact of Reduced Flow in the Duwamish River
The removal of the Renton Treatment Plant effluent
from the Duwamish will significantly reduce the flow in the
river as stated in the Draft plan.
The City of Tacoma is reported to have plans for
intercepting still more water from the Green/Duwamish system
(up-river from the Renton Treatment plant) that will further
reduce the flow. The EIS should be expanded to evaluate this
impact. As the flow of the Duwamish is reduced, the agricult-
ural runoff from lands abutting the river will become an in-
creasingly large pollution factor. Similarly, contaminations
from surface runoff from all other sources will be less dilluted
as the river flow is reduced. These problems are not adequately
covered in the EIS.
We understand that the lower Duwamish is to be dredged
and extensively developed. We see no mention of this in the
draft EIS or plan. Have you considered the impact of this devel-
opment when coupled with the reduced flows cited above? For
example, dredging and widening the river will result in a great-
er cross-section which will lower flow rates and reduce flushing
still further. The EIS should also address the impact of in-
creased salt water incursion as it affects the existing eco-
system should the development occur.
There is a question regarding the water temperature
standards during summer low-flow months. This is cited as a
problem area in the Summary EIS, however, the draft plan spec-
ifies "—this single factor is not considered of such magnitude
as to exclude discharge to the Green/Duwamish River".
We suggest that a reduction of flows is not desired.
In fact we understand that consideration is being given to
controlling the depth of the river by the Corp of Engineers
programmed release of waters from Howard Hanson Dam to ensure
adequate depth for shipping. Removal of the Renton plant out-
put would require additional drawdown of that dam.
We suggest that the management of the waters of the
Green/Duwamish River to maintain a viable fishery is much more
complicated that stated and that strong factors, greater than
the Renton Treatment Plant impact are involved. We seriously
question whether spending $300 to $400 million dollars to divert
Renton Plant waters is economically practical to save a $5 million
fishery and that that expenditure really guarantees a fishery
solution in the light of other factors.
Impact of East Passage
the imPactB8nhEa§! Pllllgl1w?t^nwhltesiimltlf51 c^ua^lfsfIgSfcl
Dilution ratio is not the issue, rather it is cumulative con-
centration of pollutants due to lack of flushing action and
recirculation back in East Passage.
(15)
(IB)
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-5-
Also the Metro planning seems to ignore the other se*er
district outfalls discharging into East Passage, both present and
future quantities. There are seven of these currently, not including
Tacoma/Commencement Bay.
East Passage must be examined as a system and data developed
to show whether the admitted buildup will be significant or not in
terms of pollutant concentrations over a period of time. We can find
no evidence of any material balance calculations in the Plan or the
EIS.
The importance of a northerly current pattern at the out-
fall is emphasized on pages 44 and 48 of the Draft Plan where it
indicates the Alki site is a preferred location ove-r -Point Pulley.
Page 123 of the Draft EIS points out that Alki is near the zone where
northerly and southerly net flows deverge and hence an outflow north
of Alki is required to ensure the effluent enters in a net north flow.
Based upon the data provided in the Draft EIS, we se no
basis for the statements that Point Pulley will give satisfactory
performance. If the performance does not turn out satisfactory,
will Metro turn off the pumps, plug up the tunnel, and move the
effluent somewhere else? It seems to be a very expensive gamble
for a "probably satisfactory" design.
Impact at Point Pulley Outfall
The Draft EIS (page 123) states that additional studies
are needed at Point Pulley to "determine local tidal current patterr
and risks of shoreward transport of dilluted effluent." The Draft
plan (page 18) indicates that studies have already shown that an
ALki outfall would have "minimal shoreward currents." In the
absence of data at Point Pulley, we again feel that any recommendation
for an outfall there is premature.
At the January 13th Burien workshop we were told that a
Point Pulley outfall would be 3000 feet long and terminate in 200
feet of water. Will there be a problem in attaining this length
if the depths exceed 200 feet?
It has also come to our attention that chlorination may
be required right at the outfall in addition to Renton due to the
relatively long residence time in the pipe. What environmental
and cost impacts would this have on the project?
ed
20
-6-
We believe tla t the environmental impact of all the propo=
alternatives has not bfe adequately determined and that additional
work is required consistent with the Objectives of the Clean Water
Act which says performance is the criteria and compliance is
required even at a higher cost.
Ill - Cost Analysis
When one considers the tolerance on cost estimating
proceedures, we believe the data presented does not show enough
cost deviation to clearly prove one alternative is better than
another. The Draft plan appears to include costs that allow
some existing treatment facilities to be shut down or play a
reduced part in the total Metro system, while at the same time 21
new collection and transmission facilities are being added. The
cost trades include the shut down of Alki and the diversion of
sewage from west Lake Sammamish to Renton resulting in a considerabl
cost increase of the proposed tunnels and greatly impacting the Renton
Plant's ability to meet water quality standards for the Green River.
For example, if the Alki plant were left in operation (possibly
with the outflow extended) the tunnel from Renton to Puget Sound
could be made smaller and the total costs would be reduced.
The Point Pulley alternatives involve 2% to 3^ times the
length of tunnel required for the Alki alternative. Tunnel
construction involves unknown costs due to geographical considerations
not yet evaluated, hence the geophysical cost estimates for easement
acquisition do not look right since it shows a 5300,000 for
Point Pulley vs $200,000 for Alki whereas the map shows easements
of 250% to 1,200% greater lengths for the Point Pulley alternatives.
Can you explain this?
We have recalculated the differential capital cost between
alternatives A-3 and A-5 based upon not closing Alki and correcting
for pipe size requirements and a reasonable correction for easement
costs and find the $78 million difference is reduced by about $42
million for a difference of only $36 million.
Should the proposed development be continued and effluent
added to the East Passage area, there is no indication of the impac
on the local sewer districts. If Metro is controlling the water
quality assessment parameters and recommending caps on State water
quality objectives in order to justify their own planning and cost
objectives, how do we determine the basis for these extra costs?
For example if the 144 mgd added effluent forces the conversion of
22
231
24
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-7-
local sewer plants to secondary treatment, all the extra costs
must be handled by the local patrons. It is unfair for Metro
to both take most of the grant funds and cause expenses outside their
area by this 201 plan. Funds are going to be scarce. The 1981
FY State/EPA Agreement states in part—Executive Summary, Page 5
items 3 & 4 under Municipal Waste Water 3.' Erratic Federal Funding.
Washington's allotment of Federal funds has been irregular and
steadily decreasing since 1976. ".and 4." The original allocation
of Washington State Referendum 26 funds available for waste water
projects will be obligated to state construction projects within the
next two years." Where will the funds come from to cover conversion
to higher treatment classifications in the existing outfalls?
IV - Summary
It appears that Metro is trying to solve a 20-year
problem with a single macro solution. We believe that the
current approach based upon the Lake Washington Basin Federated
Plan of 1958 does not take into account the changes since that
date. A Three Tree Point-Point Pulley outfall solution pro-
posed in 1958 prior to the creation of Metro does not rec-
ognize the development in the East Passage area since that date
and the changes in State Law that required the development of
a King County General Sewerage Plan. It is obvious that Metro
only has a geographically oriented planning power within its
natural drainage basins. Other drainage basins outside of Metro'
purview are served by Sewer Districts specifically set up to
provide service to that area. We feel that Metro's shifting
of sewer and surface water pollutants to our drainage and service
area without any of the required impact considerations (see SAVE
vs City of Bothell*) or the planning procedures required (see
Barrie vs Kitsap County) constitutes 3 violation of our property
rights. We feel that the Metro Council should be advised that
transferring pollutants to another drainage basin without adequat
planning and impact assessment is inconsistent with existing law.
We believe that any decision with respect to use of the East Pas-
sage area must at least be delayed until the final NOAA report
on the Puget Sound Basin and its drainage characteristics is
complete.
Recommendation
It is not logical to allow the construction of the
Redmond Connection which will divert at least 75 mgd to the
*89 Wn.2d 862
-8-
Renton Treatment Plant. This would require the doubling of the
Renton facility while precluding further development in South
King County in the Green/Duwamish Valley. By proper planning
and location of a new plant in the North County, Metro should
also be able to prevent the failure mode that results in dump-
ing raw sewage into the Sammamish River. We strongly recom-
mend that EPA/DOE disapprove the planned Redmond Connection or
any other connection that will bring sewerage from north of the
existing lines in Bellvue to the Renton Treatment Plant.
We request that EPA ask that the Metro Lake Washington
/Green River 201 plan be split into: "South Lake Washington/
Green River 201 Plan" and "North Lake Washington/Lake Sammamish
201 Plan" and that a better plan be developed to meet the needs
of the North King County area.
We recommend that the Phase I development of the Renton
Treatment Facility be a capacity growth to the maximum carrying
capacity of the Green/Duwamish River as a determined by the
Corp of Engineers flow rate controls. We assume that any devel-
opment in the lower Duwamish will be done with Corp of Engineers
approval. In addition, the equivalent solid waste processing
capability should be added to help off-load West Point. As
we see it. West Point is not operating as a normal primary
treatment facility when its process waste is concentrated by the
sludge from the Renton Plant. There is continuing need in the
Kent Valley for land fill so that there should be plenty of appli-
cation for the residual solids.
Further action on the 201 Plan should be delayed until
completion of the Final-Enviromental Impact Statement. Per WAC
197-10-055, the purpose of the EIS process is to provide env -
ironmental information to Governmental Decision Makers to be
considered prior to making their decision. The process should
thus be completed before the 201 plan is completed and prepared
submittal to the Metro Council. At a minimum, a threshold deter-
mination and required EIS shall be completed prior to an agency
committing itself to any proposed major action.
Should Metro desire to continue with their proposed
plan to route effluent to either Point Pulley and East Pas-
sage or to expand the output at Alki, a 201 study of the East
Passage area must be first completed by King County. We request
that EPA/DOE consider granting King County the fundsnecessary
to cover the costs of preparation of an East Passage 201 study
29)
(30;
*93 Wn.2d 843
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-9-
and also provide appropriate support for contiguous areas in
Pierce and Snohomish Counties. If Puget Sound is to become the
primary receiving waters for effluents we feel that extensive,
well planned and executed planning and monitoring systems should
be in place as soon as possible.
We would appreciate your attention to our concerns.
We hope that you realize that we were only advised of the
hearing and response period three weeks ago. We wish to iterate
again our great concern and disagreement with this planning and
public review procedure where we, as primary impacted parties,
were completely left out of the process.
Very truly your
Puget Sound Water Quality Committee
K.W. Smith III Pres.
a *
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Ficure 1
'.ter Cudliry Xcr.i-orirc Hii-icr.s
'.' E T R C P>0 L I T A '1 f '; C I', £ £ RS
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Response to Puget Sound Water Quality Committee Letter
of February 14, 1981
1. An "Environmental Checklist" is a requirement of the
State Environmental Policy Act. The federal EIS prepared
by EPA will serve to satisfy both the National and State
Environmental Policy Acts. Rather than preparing a separate
environmental checklist, Metro will formally adopt this EIS
as compliance with SEPA.
2. Under the National Environmental Policy Act, EISs must
fully disclose all potential adverse impacts of a project
and describe mitigation measures to avoid or reduce such
impacts. There is no requirement, however, that a project
be disapproved merely because it has unavoidable adverse
impacts. If unavoidable adverse impacts remain, the respon-
sible official determines, in consultation with other agencies
and the public, whether project benefits outweigh these adverse
impacts. In this case, EPA will work with Metro to ensure
that an environmentally acceptable alternative is selected
and needed mitigation measures are implemented.
3. DOE anticipates providing a draft NPDES permit for the
Renton discharge to Puget Sound by December 1981. There
would then be a review period of 30 days or longer before
this permit is finalized. The effluent limits would be stan-
dard secondary. These require 85 percent removal of bio-
logical oxygen demand and suspended solids, and no more than
30 mg/1 of these constituents.
4. See General Response Number 14. A public meeting was
held in Brien specifically to obtain input from Three Tree
Point area residents on the draft plan and EIS. The residents
were also notified at that meeting, and in the draft plan
and EIS, of the opportunity to formally comment on the draft
plan and EIS at the public hearings in late January 1981.
5. 40 CFR 124.58 refers to special requirements for general
NPDES permits issued by EPA. Since Washington State administers
its own NPDES permit program and since, in the case of the
proposed Renton outfall, a specific rather than general permit
would be issued, this section is not applicable.
6. See General Response Number 13.
7. While Metro's jurisdiction includes all of King County,
Metro's enabling legislation allows Metro to provide service
outside King County by contract with local agencies. There
are local sewerage agencies within King County which are
not part of the Metro system, i.e., Vashon Island, south-
western King County, cities in the Snoqualmie Valley, etc.
If diversion to Puget Sound is a part of Metro's final
plan, which is approved by the federal Environmental Pro-
tection Agency and the Washington State Department of Ecology,
Metro could then design and construct the tunnel and outfall
to Puget Sound even if the tunnel/outfall were located in
an area not served by Metro. Metro would, of course, have
to secure the appropriate easements and permits regardless
of the route selected.
8. The joint hearings were intended to provide citizens
with a formal opportunity to make their views known to both
Metro and EPA officials. Public views are to be carefully
considered in the decision-making process of both agencies.
Joint hearings were held rather than separate hearings because
it was felt this would make the relationship between Metro
and EPA decisions clearer to the public. Also, see General
Response Number 13.
9. See General Response Number 4.
10. The King County Sewerage General Plan is an element
of the County's Comprehensive Land Use Plan. The Sewerage
General Plan designates those portions of unincorporated
King County to which sewer service may be provided. The
Sewerage General Plan does not affect the selection of an
outfall site for the Renton treatment plan. The Sewerage
General Plan specifically states that "...the location, level
of treatment, and receiving waters for Metro facilities shall
be as determined by the Metro Council" (Section 2.5, A,
page 12).
11. See General Response Number 14. As to the triggering
mechanism, the purpose of the "triggering mechanism" is to
provide advance notice for needed expansions or additions
to the Metro system. It is not designed to resolve waste-
water management issues at the local level. However, the
triggering mechanism will report the results of Metro's water
quality monitoring program in the vicinity of the outfall.
If the monitoring program identifies a potential problem
the triggering mechanism will provide the advance notice
necessary to address the problem before it becomes serious.
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12. There is no obvious relationship between selection of
a wastewater management plan for the Renton study area and
meeting the long-term sewerage needs of the East Passage
area. If the question assumes that Puget Sound has a highly
limited assimilative capacity for wastewater that future
discharges from East Passage communities would completely
utilize, there is no evidence to support this idea.
13. Under its recommended program, Metro has deferred the
decision on whether to divert wastewater from the north part
of the study area to the Renton plan. Also, there are no
data in the Final EIS to indicate that the East Passage is
more ecologically fragile than Puget Sound waters farther
to the north, although circulation differences do exist.
14. See General Response Number 3.
15. The Department of Fisheries estimates the total annual
value of the salmon runs in the Green/Duwamish River to be
$4 million, rather than $2.6 million as originally estimated
in the Draft EIS. The Northwest Steelhead and Salmon Council
has indicated that the annual value of sport-caught steelhead
has almost tripled since 1976. The Council estimates that
the total value of the steelhead runs in the Green/Duwamish
River is about $7.5 million, rather than the $2-3 million
estimated in the EIS. Thus, the total annual value of the
Green/Duwamish River fishery, in current dollars, is probably
over $10 million, rather than the $5 million estimated in
the Draft EIS.
If the Renton treatment plant is expanded without diverting
flows to Puget Sound or alternatively providing an advanced
level of treatment, a portion of the capital cost of proposed
alternatives would be saved, but the very existence of the
salmon and steelhead fisheries would be jeopardized. As
flows to the treatment plant increase in the future, the
entire $10 million annual value would be at risk and could
be permanently lost.
Alternatives calling for diversion to Puget Sound also
can be compared to Alternative A-l, which recommends expansion
of the Renton plan, an increase in the treatment level to
nitrification and continued discharge into the Green/Duwamish
River. The savings between Alternative A-l and the least
expensive diversion alternative is $12 million (present value).
In this case, the immediate threats to the fishery — ammonia
and oxygen-demanding wastes -- would be reduced, but fish
migration could still be adversely affected by temperature
increases and treatment process upset, though probably not
to the point of threatening the entire value of the fishery.
At a discount rate of 7 1/8, it would taken an average annual
loss of about $1.5 million to the salmon and steelhead fisheries,
for 20 years, to just exceed a present value loss of $12
million, thereby more than eliminating the cost savings of
avoiding diversion to Puget Sound.
The State Department of Fisheries estimates that, as
a practical matter, the Green/Duwamish salmon and steelhead
fisheries could not be replaced if lost. Therefore the cost
savings associated with less protection of the fisheries
could not be used to replace resulting fishery losses.
Although the discussion at public meetings and in the
Draft EIS has concentrated on the economic value of the salmon
and steelhead fisheries, other costs of water quality deterior-
ation should be considered. These include the economic losses
to bottom fish in the Duwamish River and estuary downstream
from the treatment plant, loss of investment in state fish
hatcheries upstream (estimated at about $4 million), and
the nonmonetary, aesthetic costs associated with losses to
the salmon and steelhead runs.
16. See General Responses Numbers 1 and 2. Pollutants would
not build up indefinitely in Puget Sound because a net exchange
of Puget Sound water with the open ocean exists due to estuarine
circulation patterns. An analysis of the cumulative pollutant
loadings to the southern sound (south of Alki Point) is pre-
sented in Chapter 6 of the Final EIS.
Although the EIS predicts no major water quality impacts
with a Seahurst Park discharge, if ongoing monitoring were
to indicate the potential for water quality problems, appro-
priate action can be taken before the problem becomes serious.
Several options are available for the Renton outfall, such
as: extending/redesigning the outfall; increasing the level
of treatment; requiring stricter source controls/pretreatment;
and setting an upper limit of less than 144 MGD to the Renton
discharge. DOE also plays a role through the issuance of
NPDES permits to all municipal and industrial dischargers.
If monitoring indicates that problems are developing, DOE
can require that dischargers take appropriate remedial action
through the NPDES process.
17. See General Response Number 1.
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18. The statement that the outfall should be 3,000 feet
offshore in 200 feet of water is an initial estimate of the
distance and depth necessary to avoid the influence of eddies
in the vicinity of Three Tree Point. Detailed oceanographic
studies will be used to develop the design criteria for the
specific depth and distance of the outfall. The intent is
to design the outfall in such a way that good mixing and
dilution will be achieved.
19. The residual chlorine level will be less than 0.01 mg/liter.
The effluent limit for chlorine in the existing discharge
permit for the Renton discharge to the Duwamish River is
0.5 rng/liter. EPA's ambient water quality criterion for
chlorine is .002 mg/liter. The Renton effluent of 0.01 rag/
liter would meet this after 100:1 dilution. Although adverse
impacts from chlorine residuals are not expected, monitoring
will be done for chlorine compounds.
20. Additional water quality investigations have been performed
for the Final EIS. These studies verify the Draft EIS con-
clusion that no major water quality impacts are expected
with a Seahurst Park discharge. Also, see General Response
Number 15.
21. Even if the suggested service area changes were made,
the sizing of either the Alki or Seahurst tunnels would be
the same to provide for long-term growth. If it is assumed
the Alki plant would continue in operation, the costs of
the Alki tunnel would be reduced $15.4 million in capital
costs, equivalent to $12 million present worth.
22. Both the draft plan (Figures 2-12, 2-14, and 2-29) and
the final plan (Figure 2-16, page 46) show easement costs
for Seahurst Park at $200,000 and Alki at $300,000. (It
appears the commentor may have transposed the cost figures.)
These figures are considered accurate by Metro's engineering
consultant after a review of their analysis. The map is
not intended to be used to calculate relative easement costs.
23. See responses to comments 21 and 22 above.
24. Based on existing information, it is not anticipated
that discharge of secondary treated effluent from the Renton
treatment plant will lead to increased costs for treatment
at other local Puget Sound dischargers. Adverse cumulative
impacts to the East Passage area are not predicted. Washington
DOE, which has responsibility for coordinating the requirements
of various discharge permits in Puget Sound, has expressed
support for a Puget Sound discharge from the Renton plant.
Of Southwest Suburban Sewer District's two treatment plants,
one is already at secondary treatment. The NPDES permit
for the other plant already requires upgrading to secondary
in the future and Southwest Suburban has begun facilities
planning to accomplish that. However, DOE states that that
plant is low on DOE's priority list for upgrading, due to
its discharge to unconfined marine waters, and DOE has recom-
mended that facilities planning be discontinued until a future
time.
25. There is no evidence that development in the East Passage
area, and resulting wastewater discharges to Puget Sound,
have used up the sound's assimilative capacity for wastewater
discharges. The King County Sewerage General Plan leaves
to Metro the primary decision-making role regarding waste
discharge location, and the Metro plan is consistent with
the service areas shown in the Sewerage General Plan.
26. See Response Number 7 above.
27. The results of the NOAA investigations, which are basic
research studies rather than impact assessments, are highly
unlikely to change the decision regarding the discharge loca-
tion for Renton effluent. It should also be recognized that
delay is not cost-free, in that degradation of the Green/
Duwamish River would continue to worsen while awaiting results
of future studies.
28. The final plan recommended program follows this recom-
mendation by deferring to a later time decisions about where
to treat and discharge flows from the north part of the study
area. Also, the probability of an emergency bypass at the
York pump station, in the event the Redmond connection were
built, would be very small because emergency power generation
equipment would be provided.
29. The final plan follows this recommendation, in that
it represents decisions only for the Renton treatment plant
service area. Final decisions on wastewater management for
the north part of the study area will be made as the previous
EIS for Metro's Puget Sound plant configuration is supple-
mented and finalized.
30. See General Response Number 3.
31. EPA is following its standard.procedures regarding a
final decision on the plan. The EPA decision will not be
made until the Final EIS is released for public review and
comment. Following review of public comments, EPA will issue
its formal Record of Decision.
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32. See General Response Number 4.
33. See General Response Number 14.
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RESOLUTION OFrOSING METRO WASTEWATalt DISCiURGi; INTO LOWER FUC5ET SOUND
WHEREAS, Metro proposes to dump lUi million gallons a day of effluent into Puget
Sound North of Three Tree Foint, and
WHEREAS, the area South of Alki foint has little water movement, studies indicate
that up to 25 percent of the '.:atc.-r doesn't leave the area, tidal flow is to the
South (th.ere is so.T.e flood but littli ebb) and water doesn't flow Korth until it
reaches th.e West side of i/ashcn Island, and
WHEREAS, this area by ,-Ietro's oun description is it&terially different from West
Foint and other areas being used for comnarison, and
WHEREAS, already the negative impact of the Les Moines Sewer District and the
Southwest Suburban Sewer District on tne Sound with an increase in water temperature,
rise of the effluent w=ter and solid materials to the surface floating on the
salt water and congregation of bir'-is, and
WHEREAS, three of tha proposed sites are onto and into a unique area with a beach
front and area catering to quiet fa,dly uauage both beach and water, and an
area of unique fish and fov;l, ana
WlERcAS, the fourth location - Alki - is already impacted and dumping the effluent '•
there is in an area already effected by urbanization, and
WHEREAS, the EFA's study indicates tuere v;ill be localized increases in turbidity, •
anraonia and heavy metals — many t::tt r.re dangerous to life, and
WHEREAS, the Alki area has much rners rsT)id water movement, this movement is to
the llorth and will carry the effluent much nore rapidly to the Ocean according
to the EFA study and personnel at the University of Washington, and -:
WHEREAS, the Alki site could cost uy to 20 to 25 percent more it still does not
carry the gamble to human life and ti»e environient, and
WHEREAS, this proposed project ccu^C materially and negatively effect the long
term development of South Kii\ County, and
WHEREAS, tbj.-re are indications tfa: 1 tLe v.ic'Rning of the Duwamish River channel
to 250 feet could have increased silting and problems if the effluent water was
renoved.
NOV.1 THEaiFOIiE ii£ IF. liESOLViL, thi. t -,.«. op-50£s the locution of this effluent outfall
at other than the Alki location or r.u= pr-j£o:.L Hirer, urge our legislators and
congress members to oopose funding ^r.Vitn ta other than .the Alki or Duwamish River
location end call on the £?A to 3u- '.-.r1 otr.^r alternatives unless they are North
of Alki Foint.
• Adoptod at a regular meeting or ti... 31.-'. ijstrict Democratic Organization
February 10, 19E1.
Response to 33rd District Democratic Organization Letter
of February 10, 1981
1. See General Response Number 1. Even though 25 percent
of the water may recirculate around Vashon Island, all water
eventually does leave the south sound. The equilibrium con-
centration of effluent, with new effluent entering the sound
and old effluent leaving, would be about 0.067 percent,
assuming 1,500:1 final dilution.
2. Impacts of the present outfalls may be attributable
to less efficient treatment and disposal facilities. For
example, the Des Moines Sewer District and the Redondo sewage
treatment plant outfalls discharge only primary treated
effluent. The Renton effluent will be secondary treated.
Solids and floating material will be removed in the treat-
ment processes.
3. The beneficial uses of the shoreline near Alki Point
and the effects of the existing discharge at Alki Point have
been recognized in Chapter 6 of the Final EIS.
4. Although the EIS predicts localized increases of certain
pollutants in the immediate outfall vicinity, it predicts
that these increases will have no major adverse impacts,
other than possible accumulation of heavy metals in shell-
fish in the immediate outfall vicinity.
5. See General Response Number 1.
6. The means by which long-term development of south King
County could be adversely affected by the Wastewater Manage-
ment Plan are not apparent.
7.
See General Resoonse Number 3.
Carol 3. Hose, r.r.vircn,.ir:t uhai
229 S.W. 183rd
Eeatths, Wasringto.-] >c!6£
ENVIRONMENTAL EVALUATION
BRANCH
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TC:
A77T.!:
Waste Y/ater nanacanent Study for Lake Washington/Green Ittvor Basins
Henton 201 Study - Public. Kear'ns 21 Jonu;iry 1?81.
I'.etro Council
821 Second Avenue
Seattle, .'A 93104
Gerry Larrance
1) Vaste '..'ater IConorjement Study La':e '..'ashin^-ton/C-rean rdver liasins
(Draft -rlaii) Deoe^bsr, 1?2C
2) ::atro ",'aste '.fetor ;iana-;enent/:ar;.ft 3nvironn>2ntal Impact 3t?.toaent
I 2.-?. Tor: I.iller, I represent the South :'J.i\g County Chapter of the ITortlMect
itoalhs'-cl C: jalnoh Council. '.3 v.'ish to n^-ca our stated-ant both or.-.lly here
to:iita and -.fill submit -.-.'ri.tan copies at this time.
. ?irst a basis for our input, "is have a vested interest in the Graen/Duv;a:nish
?.iver. Cur Chapter w_a fo:— ,ad in 1 .~59 -Ji- adoy-tad" the Graen ?j.var for orojaot ;".a-
v:-lcp-.:.::--t. In '\~"1'\ wa .".evolopod c. rearing facility for GhinccC; oil-on it j'cy
Cro=I; iii the Grcan ?JLv=r Cor;e. The pro^-rc.T -.-; s such a success, the Jtr.ta jlshsri
Deportment too): this facility ovar cn-d has exp-anded it .into a fulltiue ..-iluon
facility. ?or cuv success, tha Chapter rc-caivad "rout ;,nli:'.iteds' C-oldan '.rout
.'.-.'ori. It is a nation.-.! oi'ard civan a-inually to tho organization thai c.oes the
~Ct:t for the cold v.'a.t&r iTisCiar;,'. •
I7a::t, in 157S, v.-e -.;ent In ocoparntion -/ith ./as'-in^tcn otate i'arhs Japirtnent and
ths TrT-.-a 3:p2jrt-:ent i~to Tlsains Geyser Sari and turned soms broher. ciovm old Tr-.ut
po-is br-cl; in^o usable" structures. '.;e ths:i be.j-r-r. a 3teallie-.-.i Inrrir.t l:ro T^;." in
v..ich :s ar-.ually introduce 15.CCO --.-inter r-jn 3teelhe:-.d and 10/.OQ surfer ~vn
.')t-3aHie .d into tha 3raa:i liiver. ".;e continue this successful pro..T2--n each ye~-r.
In 1J73 v:e st^jtsd a joint pro_7x?,n ".;ith the Graen Mvar ot3alha?-d Club in coop-
eration '.'ith the G?.T.e Japirti/ient, capturin-3 '..'ild and native Jtsslhead. Ti:is -ic.3
d:.-.3 in the Green _;ivar and the e-gs usad for prop-gation. By using this aatio.'L
::s h?.V2 cut e;;r7 mortality by 80, > and started the Graen lliver n'itivs stochs b?.clc
cr. the incr2i~3. Last ye_o: ';e rile^s^d 1.0,000 fry fron this p-'OjTan and are
•..-sr.iin; for 450,000 this ye;j?.
.ill th.2 n?ji hours, oqv-ivnont and gasoline are at the individual expor.se of the
"s .bars for all thass projects. ..'e feal -.;o hrive earnad the rijiit to be concoiv.jd
z'ocut the Green Itivor.
! c-..' to the busir.asc ;it hand. Cur objective in respect to the Green/i/U'.;ani3h
7.i var is Multi-fold and as follo-./s:
1) EreGsrvation rj.d further enliancenent of this valu?.ble fisher;/'
2) Continued developnant and pros^r\'?.tion of this valuable resciirco
for total public rocx-^j.tion
3) To -/or!: -;ith local, state and federal a.^eiicic-3 to ar.sure tlv.t the
f ore -.-'in- objectives oi-e attained end that the tuilic inte.:ests in
this rosourcs are protected.
Th2 -;r:nci'-lo th.rv.ot ot our ob;3ctivos o." presar'/ation .in.: sr-i-^!c::r.ont Q-~ the
"'2. .=ry h '.va b -0:1 a in-' rrJ to by I'.etro in rsfe •.•a.ics-i •.".ocu'^ntr:. !:0'.;ov2r, to
ji-lr.'.1 ..:o."- vivid focus -an' speciric or.iph.a-i3 to t'.:e public ../.d provide :no..'e
';---.il-3i f?-=os for tho pu'-.lic r.icord t';:e folio :inc su;j.'.-!ary a.!L. claocript.U'r of
-2-
»^ea (of t is type) in tha st-.te of './as: injrton. Adjcoe-t to the rivsr is our
no-jt populated araa. Tlie demands upon t'.'i:: ri'/er by the recraation-ori^r.ted
populous ic trj-ieiCouB and hn.v.3 increased ten-fsld in t'.ia past 5 ye-.ra and will
continue to incres.se at this rats for the foresc-ea'rile future. Contir.uad ro.:id
population -jrc;-.;thf siier^y cos.s, loss of other fishi-'iss sach as the ?outl2 .'.i/ar,
a:rl the evDr incre-.nin; -.-.iblic inLsrest are a-.;or oontributinj factors to thin
' intensa d-3 -L^d. The CJrssn Ilivjr provides t'ue principal "os.i-.ity -nl character -;..a
valley citias OQSSJJS. 'ithout the rivar the vallo" citiss s:d.rtin^ its b«v-s
vfoul-i ba qui'ce ordiaui™' ani pe haps evsn dull. CJD a^".y tr-.:;2 it for ^T._-tad.
Tha Graen '.liver is considered a n?.^oy yerjr-raund ni.;rr.tor7 flal.ery. It is
sii-nific:uit to note th_. t thera i:: miyraticn of suri-ir run Jt;-ejhe.'.d Vrcut
;.ay-jL\t., ,'i:it-r i-.m 3t-2olhs..d -jrout _"ov.-. ar. , "Tr.tive r-jn -t2jl!:e ..". ,'rr.ut
ilar.-l'ay, ?all Chinook (L'inr;} 3al:.:on Sapt.-C-ct. and Coho (Silver, 'Jalrion
Cot.-"7cY. I>.i..-inr; the on'':i-.-3 ye-r there ave lit»rally hunthc'-ds ci' iho-j.; -,.-_is
of finj-srlin- fry cjid s.-jolts or the^o species prisa.it in the river.
Metro's 1>76 CO--.T; factor of t is fishery is less thr^i onj half .:hat i"; is
today. Sport cr.u^it Jt;a"heads valua alona has almost trijlsd since 1?7o. '-'o
£i'.re you insi. ht ".s to ho • th.is is fi ur^d ?j"i:". -.''.i^t an i^p .ct ::cv.ld ^ff act, I '.'il
aiipl-Lin. r?,'.-e t'ie t^.c..lo (all acco'.mtr.blo bic.-_u-e of cpDciol tr-csr) bo?.''.s,
-o'.crs, fual ilr:o:i harvest credited to the Green nivsr has al::c ezcslli-ratai sir.^c your
fi"ures v.-e.e t->;er.. It h-.s doubled since 1975 in dollar valus.
To vrut it bluntly an iinp-.c*. to the Green Paver -./ill ba felt both by the business
co~-j.".uiiity and oports:':ian alihe.
I:- confomanoe ts tha Clet.:'; ','ater Act, re;julai\on astablishe-- by "..:^or'C"sr.t of
rjcolo;.y, aad otindards fur'iished by the itivircn-_-;nt-J. Irotectior; Aja icy, I-:etro
is ra-;-.iii-.d to cciifor..-. to uiniTsun tra?.t.-5:it of \.-a3tev-ater at t'.ie .".eaton 'Jrsat'.n.t
Tl .r.t. "Jhs cu-Tsnt volu,.na traatoi i.T approirlnataly 41 ..C-FD. ?la:-_t cr.aoi.ty is
Jo ;:ii"O. ?ro_orly esu-.tod ^'nis aaa.is th-.t current treit-.er.t dcas not acv.i'or i
to 3t:n:'.ards and ra^ul.'.ti .ns established.
If tlia str-tdar-is and regulations are to be na.?jiin.-;fiil or.:i thus act-.xally t:.e
la'.;, it ca:i be as'::jnaa t'-.ay are a basis of authority for ,.o.ro. Ir. vie-/ of -chis
in":er_jr-otat.'.on, Llie fcMo-.'in;;; raco:; iei-ojiti ns ^.*e ux'.e:
1) Adopt al bsrn-.tivs A-3 or A-5 '.in order of prefo-raiice; •.•-e.ste-..'.ter
outfall. Sitansivo studies disc.".c-j2 :xo inpact on r^-_:iro life,
t -e environ-.ont or the aesthetics
2) Until (1) abovs is fully oparr.bla i -.pose a "oe.;er ~ooh-up" Earitorva.::
on all industry or burinass -.-hich -..-ill tspoas ch-a :lc-.l t-clvsat, or
ot>.ar.'i:-3 to::ic -./--.rto and/or cffr_-.:;:-.t to tha Canton ';raat-.::-t ^1 _;t
7acility. This r.o-.-it>:riu;'.i shoulc. ba inr-sdi-.ts -.3 th_- prerj-.it
fr.cility if alr-a-.i-; overloaded. "71A and DCJ st:c-_dar-Is and rejUl .ii^ns
should provi '.e a-.ipl-j authority for 'this action. If ; sy c ui aut..or-.:-.e
new constr-action, thaj- o-in stop it.
f) Accalerata curra. .t scl-o;.ulss to porait CGr-struoticn cc-^loii-.n I
prior to 1.~35. |
(D
Vha "roe"1, r.ivor h".3 become perhaps tho nest i \-ort?.nt fishery .and racrisation
-------
-3-
It is cur ietOL-nin-'-tion ?.r.d intent to r.= int in, protect iiid i..prove t'.'.is resource
b;' 2.11 r.3-uia aviil-ibio. "opefully our in-put :ill bo constructive --r.d cro.-.te
& ™s--:?r c.-..-a"o:-.3."3, int:-_-3rt ?_-.d .".ecive by the public, ir.c'us"—.- and r^-ticio-tir.-
GOVJ .•.•-.er.tr.l r.-e.'-CiDs to nr;3«>L-v3 the Croon Ilivcr.
Ron Dunlap
King- Co. i{ec.
:;e.-.t Ci-y Cc-jr.ail
:-\ic'.:l:-s:;oot Cribe
B.0.2.
E.P.A.
. feout TJnlinited
K.W.S.JtS.C.
Wash. Qiviromental Council
Groan Peace
Citizens Co^nittee ?or Cle^n Vfeter
Scm .allrr
Jc:-3s J. Lson-.rd
Boc^-d of Jir-:ctcrs
:T-'"'- Steelhe .d i: SaL-.on Coimcil
L^oulh J !in^ Co. Chapter
Response to Northwest Steelhead and Salmon Council Testimony
of January 21, 1981
1. The resource values of the Green/Duwamish River have
been recognized in the EIS.
2. The Final EIS contains updated cost factors recognizing
the increases in the Green/Duwamish River's fishery value
since 1976.
3. Although current flows are above the plant's rated capacity,
Metro, by stressing the treatment system and employing contin-
gency measures, is able to meet the requirements of its current
effluent permit.
4. The final plan recommended program is a variation of
Alternative A-3, in which Renton effluent is diverted from
the Green/Duwamish River to Puget Sound.
5. See Response Number 9 to Citizens Committee for Clean
Water letter of February 16, 1981.
6. The final Metro plan includes the proposed construction
schedule in Figure 3-10.
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CITIZENS
399
-------
January 7, 1981
Dear Mr. Partridge,
Don't dump that dirty waste In Puget Sound. I'm willing to pay
for higher levels of treatment so the liquid waste can be dumped any-
where safely. I only wish thpt others could be convinced that In
the long run It will be safer and perhaps even cheaper. I don't
wpnt our beautiful body of weter affected ss It moat certainly will
be.
There are many subtle changes made before fish die and clams
are poisoned. Consider the food chain. Who knows which small
organism Will be killed and thus breaVs the chain? Who knows which
cs&anlsm will develop toxic levels of tSls or that affecting the
chain? Every year levels of substances previously thought to be safe
are found to^be harmful. How can you presume to take- Into account
all the unknowns? And If you agree there are unknowns, Is It worth
the risk? I would think we have enough toxins floating around In
the sir and water to worry even the most unobservant. But this Is
a blggy and one that could be averted with less trouble than moat -
a few more dollars a month. I feel It would be very near sighted
to dump the waste ns planned arid that there would be major raml-
flcntlons In the years to come.
Response to Patricia Morris Letter of January 7, 1981
1. See General Response Numbers 1 and 2.
?t&€
EPA-RS
-------
2106 47th Avenue SW
Seattle, UA 98116
January 9, 1981
ENVIRONMENTAL PROTECTION AGENCY
Region X
1200 Sixth Avenue
Seattle, WA 98101
RECEIVED
JAN 12 REC'C
EPA-BS
ATTN:
Mr. Craig Partridge
M/S 443
Dear Craig:
The METRO expansion presentation at the Alki community meeting on January 6
was conducted in i professional manner and was, I believe, very effective
in determining citizen opinions on the program.
Two comments during the meeting were of particular interest to me. Mr. Bauman
of METRO stated that "all five (sic) options presented were acceptable in
terms of water quality.'1 Mr. Herson later stated that "circulation differences
between the two choices (Point Pulley and Alki) may not be significant." The
import of these two statements is that they make the $78 million cost differ-
ential favoring the Point Pulley alternative more significant.
I believe that the environmental impact process to date has failed to focus
on the real quality of life issues associated with the locations selected
for the METRO project. As I attempted to point out in the meeting, quality
of life is very much a function of the perceptions of the community, and
despite any scientific evidence, the quality of life for the residents of
Alki will be diminished if METRO were to construct the large scale sewage
outfall project in their community.
The environmental impact process should take into consideration the nature
and structure of the communities where these projects are envisioned. With
a little study, I am sure you will agree that the Alki area has had more
than its share of unfavorable circumstances for a residential community
including environmental, social, and developmental impacts. From the environ-
mental viewpoint, the community has suffered from odors from the existing
treatment plant, shellfish toxicity, "red tide" beach closures, and landslides
There are some serious and continuous social problems resulting from the
desirable recreational nature of Alki and the proximity of the beach to
residences:
1. Vandalism and burglaries
2. Litter
3. Excessive noise from recreational activities
It. Youth alcohol and drugs
5. Traffic congestion., air pollution, and noise; -motor vehicle speeding
on residential streets.
Mr. Craig Partridge
Page Two
January 9, 1981
Finally, there have been pressures to increase the residential density of
the area ranging from condominium developers to proponents of high density-
low income housing.
As an admitted layman in this field, It is difficult for me to comprehend
how the marginal benefits of water circulation would justify the expenditure
of an additional $78 million to construct this project in Alki. I believe
that the negative impact on the perceptions of Alki residents and indeed on
the thousands of recreational users of Alki is a decisive agrument against
the/selection of this alternative.
Greg Schuler
West Seattle Resident
Hon. R. R. "Bob" Grieve, King County Council
State Senator Phil Talmadge
Mr. Jeff Bauman, METRO
Hon. Jack Richards, Seattle City Council
-------
Response to Greg Schuler Letter of January 9, 1981
1. See General Response Number 1.
2. See General Response Number 8.
3. Metro's Wastewater Management Plan evaluation agrees
with this observation, in that overriding benefits of an
Alki Point discharge were not found which would justify the
increased costs of this alternative.
-------
January 9, 1981
15 19B1
Dear A*.' •/<"<-•-"7 -, BWMJiMEHTW. EVALUATION
BRANCH
We attended the Metro meeting held in the Alii Congregational Church
Tuesday, January 6th. We are in complete agreement with those speakers
in the audience who protested the Metro plan to tunnel through West
Seattle and enpty effluent into Puget Sound.
We are strongly opposed to effluent being emptied into Puget Sound
at any location.
New developnent in the Greater Seattle area is almost inevitable, with the
result that; if the pipeline project is carried out as planned, an ever-
Increasing volume of effluent will be released into the Sound to the
point where marine life is endangered, as it Is now endangered in the
Duwamish River, and recreational areas become obnoxious; at that time,
when there is nowhere else to go,Tertiary Plants will become a vital necessit; •
We believe that Tertiary Plants are the only feasible and final solution
to this problem, so let's start building now before inflation makes it
prohibitive. Please stop spending time and money researching plans
which may well become obsolete even before they leave the drawing board.
Thank you for giving us this opportunity to express our opinions. Believe
us, we are sympathetic to your problem because it is also our problem.
Disadvantages of Pipeline project
Irrevocable damage to Puget Sound waters.
Possible damage to existing adjacent properties.
Soil conditions in West Seattle (unstable terrain).
Drainage and Flooding caused by disturbance of natural drainage areas.
"Cave-ins" due to heavy rains or snou.
Earthquake hazard. West Seattle lies on an earthquake fault.
Disadvantages of Tertiary Plants
Expense which is inevitable anyway in the final analysis!
Sincerely yours,
Residents of 6Oth Avenue SW
Response to Residents of 60th Avenue Southwest Petition of
January 9, 1981
1. Damage to marine life is not foreseen under the scope
of the project as presently planned.
2. The high cost of tertiary treatment for discharges to
Puget Sound is not justified because significant effects
on the marine environment have not been found with properly
designed secondary (and in some cases primary) treatment
systems. Also, even tertiary treatment does not remove all
potentially toxic substances.
3. Damage to Puget Sound is not foreseen.
Response Number 1.
4. See General Response Number 7.
See General
i^ .- V US
ic ?f*
, ,,r-//-r:n,
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JAN 13 1981
A. Hoel Kelson
3126 S.W. 172nd
' Seattle, Wa. 98166
January lit, 1981
Mr. Roger Mochnick M/S Ul»3
EPA, Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Mochnick:
Last night I attended the meeting held by Metro to discuss the proposed plan to
divert sevage effluent from the Renton Plant via a tunnel into Puget Sound.
Betveen four and five hundred people from this area (Burien/Shorewood/Three Tree
Point) voiced extreme negative reaction to location of an outfall in our commun-
ity.
Reflecting on the many concerns expressed at this meeting tvo, in particular,
seem to he of greatest importance to us.
Environmental Impact to the people in the community must be taken into consider-
ation by the E-P.A. We appreciate your concern and protection of vater quality,
but you need to be concerned also for the protection of occupied private proper-
ties at the point of outflow. Regardless of the purity of the effluent, human
sevage discharged into the sound at any given point vill have an inherent negative
effect on the property values in the area. The desirability of residing within
even a larger area surrounding the outflow is reduced significantly.
There is a need to locate the outflow in as isolated an area as possible (away
from bedroom communities).
Specifically, this speaks to a location in a commercial area such as Elliott Bay.
The most effective diffusion of the effluent once it is in the sound is a second
viable argument against location of the outfall in South Puget Sound. It is
obvious that the location of any outflow at a point south of the northern tip of
vashon Island will fOi-ce diffusion of effluent in a southerly direction. It is
equally obvious that any location of an outflow north of the northern tip of
Vashon Island is a definite best location for now and for many years in the
In conclusion, I respectfully r-quest that the E.P.A. re-evaluate the impact of
this proposal on the people environment of the Kighline/Burien area.
- 2 -
There is a need to include this evaluation in your document, Metro Wastewater
Management - S""""i"-y Draft. Environmental Impact Statement, which currently
represents an E.P.A. opinion prior to surveying the peoples' concerns. I
further encourage your department to support the best location of an outflow
into the sound which would most quickly and effectively diffuse effluent and
move it out of the sound, a point north of the northern tip of Vashon Island.
Thank you for your support in protecting our environment.
- 0. -
-------
Response to A. Noel Nelson Letter of January 14, 1981
1. See General Response Number 8.
2. See General Response Number 1.
-------
7%*;
^
,;...-. •-.:.;, ------- 25^-
m>A- ®
Response to Henry Wheeler Family Letter of January 15, 1981
1. An Elliott Bay discharge was considered early in the
facilities planning process. It has higher costs than a
Seahurst Park discharge, and Elliott Bay has poorer dis-
persion characteristics than the open waters of Puget Sound.
2. See General Response Number 12.
3. Metro has included a discussion of financial planning
in Chapter 3 of the Final Facilities Plan.
4. The final plan recommended program defers the decision
on where to treat and discharge wastewater flows from the
north part of the study area.
5. Alternatives for the West Point treatment plant will
"be re-evaluated as part of the secondary treatment waiver
process and Final EIS for the West Point plant.
6. The Wastewater Management Plan assumes a continued growth
in industrial discharges roughly proportionate to population
growth. Industrial pretreatment and toxic substances control
are being evaluated in Metro's toxicant study which is cur-
rently in progress.
Metro has an industrial waste section which administers
an EPA approved pretreatment program and issues discharge
permits for all industrial dischargers. EPA is in the process
of setting industrial pretreatment standards for toxic sub-
stances. EPA's standards as well as the results of Metro's
toxicant study will be used in establishing discharge limits
for industries which are tributary to the Metro system.
-------
January 13, 1980
!!r. Craig Partridge
EPA - Region ?10
1200 - 6th Avenue
Seattle, l.'r.shington
Kail Etop
Dear Kr. Partridge:
This is a letter of protest for the proposed Metro project of ending the
discharge of sewage effluent into the Duvanish River and piping it to
Puget Sound instead. I attended the Al'.:i.meeting on January 6th and felt
well-founded opposition was presented against the proposal.
As a long-time practicing pediatrician in Seattle with dedicated interest
and understanding of public health and preventive medical standards for
all the people, I feel that this proposal must not go forward.
We nust think ahead to more than where we will pump out our growing sewage
effluent. Although, it presents higher initial costs to build closed system
sewage disposal plants, they will pay all the added costs and more with
return on the recycled commercial fertilizers. The United States government
would undoubtedly be our largest customer to help in the development of arid
lands. The rjore refined sterilized effluent could be returned to local
rivers without problems.
Please tote that I referred to pl»nt(s). There should be geographically
strategic units built, so that the capability and reliability of the system
. would not be unduly taxed, in tines of flooding, etc., by having just one
enlarged ol^nt at Renton.
Perhaps, the Depart-ent of Interior would be interested in being a partner
in this concept and set a model for other states to follow in building for
a better tomorrow for all.
Response to E. John Wollenweber Letter of January 18, 1981
1. Reuse concepts currently incorporated in the recommended
facilities plan include recovery of methane gas from sewage
sludge, and proposed land application and composting of digested
sludge. Treatment of wastewater by advanced wastewater treat-
ment (nitrification) was evaluated in facilities planning,
and it was concluded that nitrification would create reliability
problems and still would not eliminate risks to the Green/
Duwamish River fishery. The effluent might be made still
less threatening to aquatic life through implementation of
additional advanced wastewater treatment processes, but the
costs and energy requirements of such alternatives would
increase substantially. Regarding decentralization, the
final plan recommended program leaves open the option of
building a Kenmore plant to treat flows from the north part
of the study area.
Sincerely yours,
E.^aohn V.'ollem.'eber, M. D.
ccj Metro Office, Seattle, KA.
201381
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3KM 201981
January 19, 1981
Paula E. Clark
16U22 8th Avenue South West
Seattle, Washington P8166
EPA, Region X
1200 Sixth Avenue
Seattle, Washington 98101
Re: Renton 201 Study, Metro Wastewater Management
To Whom It May Concern:
The Draft Plan Summary begins with the following statement,
"Water quality has always been vitally Important to the
residents of the Seattle/King; County metropolitan area."
We are faced in this area with several alternatives of dis-
posing of wastewater; as Metro has determined, this will be
accomplished by either Alternative A3 (Point Pulley) or
Alternative A5 (Alkl Point). This involves discharging
effluent, including heavy metals, into Puget Sound at either
site A3 or A5.
I would like to express my concern with either A3 or A5 as
sites, and most especially Point Pulley. My primary concern
is water quality. I believe that disposing of effluent from
the Renton plant will cause deterioration of the water quality
in the Point Pulley area. The fish, shellfish and swimmers
will all be continually exposed to the toxicants in the
effluent. It will only be a matter of years before the levels
will build up and cause major hazards to health. Especially
of concern to me is that as the service area widens, it will
become more convenient and "cost effective" to continue
hooking up to Renton-Point Pulley tunnel, which will grsatly
increase the amount of effluent discharged into the Sound.
Point Pulley area could conceivably become the dumping area
for the Renton, Bellevue, Redmond, Kent, Auburn, Kenmore area.
Considering that at this point most of the wastewater would
be originating far north of Point Pulley, Alternative Bl
might be a more cost effective plan to implement now.
Another factor in water quality, and one that is of major
importance, is that at Alki, there Is a shorter effluent
residence time than at Point Pulley, due to the cur-rents.
Local residents at Point Pulley are all aware of the southerly
direction -of "the current. Wi*h ^onmencement Bay in Tacoma
BS terribly polluted as it is, I do not feel we can allow
Page Two
any further pollution to flow in that direction.
If selection is based on the cost of the project, I feel
that the difference between costs of A3 or A5 is negligible.
I do not believe that a 50^ increase in the Metro charges
is a hardship.
The last factor I would like to bring up, and one that is
quite apparent to everyone, is the negative public feelings
that Metro will and has encountered. As evidenced at the
recent meeting in Burlen, there will be great public resistance
to putting the tunnel through any of the three proposed
routes to Point Pulley.
I would like to encourage Metro to vote for Richmond Beach
disposal (Alternative Bl) or Alternative Al. Either of
these plands, despite differonce in cost, would be more
ecologically sound, be of better public-service and be of
better long term use.
Sincerely,
(i)
Paula E. Clark
cc: Metro Council
-------
Response to Paula E. Clark Letter of January 19, 1981
1. See General Response Number 1.
2. Metro's recommended program retains this option.
3. See General Response Number 1.
4. EPA regulations require cost comparisons to be made
on the basis of total present worth costs. The $66 million
difference in present worth costs between Alternatives A-3/A-5
is significant in the aggregate, even if it would mean only
slightly higher monthly rates for Metro customers.
-------
January 21, 1981
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington
Response to Robin Rolstad Letter of January 21, 1981
1. See General Response Number 7.
Dear Sir:
As a concerned resident of the city of Seattle, I am totally against the
concept of pumping sewage from the county through ths middle of our
city. According to yc-r draft Cr.virorn7ief.tal Imydci. Statement two of
your proposals involve transporting unclean waste water through five to
ten miles of pipe to an outlet located in Puget Sound, Since the proposed
routes travel through earthquake fault zones why wasn't any earthquake
protection included into the design ?
®
Robin Rolstad
4613 48th Avenue South
Seattle, Washington 98118
"WWRCHMEMT" K
BRANCH
-------
E.T.A. Region X
120 • 6th Avenue
Seattle, Wa. 98101
Coi£ Partridge
Mail Stop M-S 443
Seattle, Washington
Gentlemen:
5000 S.W. Stevens
Seattle, Wa. 98116
January 22, 1981
Jeff fiaunan
Metro
821 2nd Avenue
Seattle, Wa. 98104
Gerry Larrance
Metro
821 2nd Avenue
Seattle, Ua. 98104
Re: Draft Wastewater Management Plan
Lake Washington/Green River Basins
Renton 201 Study
We wish to go on record of strongly opposing the proposed sewage
plan involving the tunneling through West Seattle and emptying effluent
off Alki Point.
As long time resident of West Seattle (and our forefathers as well)
we have enjoyed the beauty and environment of this area and wish to retain
that quality.
The plan you have in mind will only encourage developers to forge
ahead, leaving their problems to our area to overtone. If development is to
take place in the east and south ends of King County, then consideration
should be given for the consequences to be met by those responsible for
their actions. Just don't foist those problems on us in this area. We have
enough to contend with, without additional burdens of neighboring effluent.
Presently we are involved in the West Seattle Bridge project which
will be with us for a couple of years. Also, West Seattle as you may know,
is a potential earthquake area, and In 1964 we had definite proof of that.
We have no alternative plan to offer other than - not at Alkll
With all the talent of available engineers, certainly some alternate plan
could be used resulting in a better solution in the area involved.
Very truly yours,
Donald A. Mass
Maxine D. lUiss
Response to Donald A. and Maxine D. Haas Letter of January
22, 1981
1. Wastewater planning is regional in scope, similar to
transportation. Metro, as the designated wastewater plan-
ning agency in this region, has determined that a centralized
treatment system is preferable at this time and that Puoet
Sound is the most acceptable discharge location.
2. See General Response Number 8.
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S£3I52US53)(1-019046C022)PD 01/22/S1 IS49
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03033 SEATTLE WA 139 1-22 1225P PST
PVS U.S. ATTORNEY
ROO-i 1012 ' -.
U'KTES STATES DISTRACT COURT HOUSE ~^_ ' DLV
SEATTLE WA
STATEMENT: . -
AT PUBLIC HEARING, BELLEVUE WASHINGTON, U.S.A., 21 JANUARY
|9dl, NO UNSOLICITED PUBLIC ACKNOWLEDGEMENT OF CHLORINE TOXICITY
TO E:JVIRO;,VENT FROM RENTOH TREATMENT PLAND EFFLUX ON BEHALF OF
REPRESENTATIVES FROM METRO SEATTLE OR FROM UNITED STATES ENVIRON-
MENTAL PROTECTION AGENCY OFFICERS (REGION TEN) IN THEIR PUBLIC
ENCOURAGEMENT OF EFFLUX WASTEUATER DIVERSION TO PUGET SOUND FROM
*
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3
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ITS PRESENT EFFLUX INTO DUWAMISH RIVER.
'* IN ENVIRONMENTAL IMPACT SYNOPSIS FROM ENVIRONMENTAL PROTECTION '
AGENCY, NO STUDIES ON DIHALIDE ANION INTERACTIONS WITH BICMOLECULES,
® AND >!0 SUGGESTION OF EFFECTS FROM RESULTANT ACCUEOUS ELECTRON
FORMATION IN PUGET SOUND.
SUGGEST IMMEDIATE CESSATION OF CHLORINE GAS TO DISINFECT
WASTEWATER UNTIL. CURRENT TOXICITY LEVELS WITHIN IMMEDIATE
REGIONAL BIOSPHERE ARE ACCESSED AND DISCLOSED TO PUBLIC.
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W.H. COOK
BOX 4291
SEATTLE, USA
98104
Response to W. H. Cook Telegram of January 22, 1981
1. See General Response Number 19 to Puget Sound Water Quality
Committee letter. An alternative to chlorination for dis-
infection of wastewater would be desirable. Unfortunately,
no cost-effective method presently exists. A great deal
of research nationwide is currently being conducted toward
this end.
CYS FURNISHED:
WORLD HEALTH ORGANIZATION
AVE'IUE APP1A
1211. GENEVA SUISSE
3A.NK FOR INTERNATIONAL SETTLEMENTS,
CENTRAL BAHfi PLATZ 2,
4002, BASEL, SCHKEITZ
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Response to Norman Zenk Letter of January 28, 1981
1. See General Response Number 1.
2. No discharge is contemplated at Normandy Park. Seahurst
Park is the referred discharge location. No direct signi-
ficant impacts to the beach are predicted, although perceptual
impacts may exist.
3. See General Response Number 8. As to the Ravenna tunnel
cave-in, the Ravenna tunnel and proposed Renton tunnel are
not comparable. The Ravenna tunnel was of brick and mortar
construction and was built by the City of Seattle in the
early 1900s. The brick and mortar was very susceptible to
attack by hydrogen sulfide corrosion which weakened the tunnel,
resulting in its collapse. Modern tunnel construction techni-
ques eliminate the possibility that a "Ravenna cave-in" might
occur in the Renton tunnel. In addition, the effluent tunnel
should not experience a hydrogen sulfide corrosion problem
because the effluent is well oxygenated, compared to the
raw sewage transported in the Ravenna tunnel.
4. See General Response Number 8.
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: S\Q_
Response to Rita and Greer Nielson Letter of January 28, 1981
1. The Final EIS in Chapter 6 recognizes adverse impacts
of construction of the Seahurst Park tunnel/outfall, and
presents mitigation measures to reduce the severity of these
impacts.
2. These alternatives were evaluated in the Wastewater
Management Plan and EIS. Nitrification of effluent at Renton
still would not afford complete protection to the Green/
Duwamish River fishery. An Elliott Bay discharge is more
costly than a Seahurst Park discharge, and Elliott Bay has
poorer dispersion characteristics than the open waters of
Puget Sound.
*-*V^ ^
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January 31, 1981
Subject: Draft E.I.S. for
Wastewater Management
Plan for the Lake
Washington Green River
•--- -—-Basin
Roger K. Mochnick
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98108
Dear Mr. Mochnick,
Page Two
Since our children will also be paying for this decision, we must make sure it
is not made hastily and that it is the most cost effective one possible.
Sincerely,
ENVIRONMENT* BttUWIW
BRANCH
Having reviewed your Environmental Impact Statement, I feel there are some
deficiencies that should be corrected in the final E.I.S. Your contention that
Alternative A-l would ham. salmonid migration by raising the water temperture or
lowering dissolved oxygen level is not substantiated by any data. Also why couldn
the effluent discharge be cooled by refrigeration during periods of low flows in
the Duwamish? Couldn't the requiremenf*point s ource treatment for discharging
heavy metals lower the discharge of these materials to meet D.O.E. standards?
Why couldn't paddle "heel oxygenators like those used on the Thames River in
England be used on the Duwamish River to raise the levels of dissolved oxygen?
Wouldn't the elimination of the sewage discharge increase the salt water intrusion
up the Duwamish River during periods of low river flow and wouldn't this hurt
juvenile salmonids in the river? More evidence should be given in the final E.I.S
in order to justify eliminating alternative A-l, especially when it is the most
economical solution.
Inadequate soils data is given to determine the cost of boring a tunnel for
alternatives A-3 and A-5. A soils profile may give a general idea of the conditions
expected, but without more extensive investigations, unexpected conditions might
double or triple the cost of the tunneling. Without Federal Aid .that might result
doubling or tripling or sewer rates for people living in areas who wouldn't even
contribute sewage to the system.
CD
ayU^aVassar
702 West Cremona
Seattle, Washington
98119
,
in th
Alternative A-l would have less unexpected costs because it is on a smaller scale with
fewer unknowns. We do not want ano ther WPPS.
Since business, commercial and high density residential development have resulted
in the need for a larger sewage system in the area, why shouldn't the developers
of these businesses pay a proportionately larger share of the costs for these
improvements? Also, won't these sewage improvements actually incourage unplanned
development?
The Environmental Impact Statement for this project is an attempt to substitute j
an administrative decision with only a limited acount of public input, for a
political decision that should involve the local public officials and a public
referendum. The question is not how the metro rate payers should pay for these
improvements but whether the rate payers should pay for these improvements.
Especially since you may have already eliminated the best alternative (A-l) and
don't have a firm estimate of what your recommended alternative will cost.
I hope that the reviewing federal agencies will judge the present draft E.I.S. as
inadequate, and will not give approval of the final's.I.S.'until a better job of
research is done to answer the questions raised and reduce the numbers of unknowns.
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Response to Jay LaVassar Letter of January 31, 1981
1. There are essentially no data that positively demon-
strate that present temperature and DO regimes harm salmonid
migration in the Duwaraish River. The general temperature
and DO criteria for delaying migration are derived from studies
of other river systems. Sampling the precise triggering
of upstream migrant salmonids through the estuary would be
expensive and difficult. Additionally, there is probably
some variability in the response of the fish to temperature
and oxygen, i.e., the temperature and DO criteria are not
absolute thresholds which positively block fish migration.
2. As to heavy metals, concern about heavy metal concen-
trations in the Renton treatment plant effluent is not the
basis for recommending that the effluent be diverted to Puget
Sound. Even if heavy metals were totally eliminated from
the effluent the diversion to Puget Sound would still be
required to address ammonia toxicity, reliability concerns,
chlorine toxicity, dissolved oxygen levels, temperature levels,
and wastewater dilution ratios.
As to alternatives to diversion to Puget Sound, although
a full range of alternatives was considered, there is no
cheaper solution to solve the problem. Alternatives considered
include such things as in-river aeration, fish bypass structures,
in-river chemical treatment, seasonal storage, seasonal land
application, in-stream flow augmentation, direct fisheries
enhancement in the event of fish kills, and others. These
alternatives were either infeasible, more expensive or too
unreliable. There seems to be no practical alternative to
diversion to Puget Sound or advanced waste treatment.
3. See General Response Number 3. The Final EIS contains
additional analyses of effluent removal from the river. The
effluent is more of a detriment than a benefit to juvenile
salmonids due to the ammonia in the effluent.
4. See General Response Numbers 11 and 15.
5. See General Response Number 12. Regarding growth in-
ducement, the EIS analysis indicates that the proposed sewer
service area is consistent with local land use plans and
policies, and service would therefore only be provided to
areas currently planned for development.
6. The Metro Council, consisting of local elected officials,
will make the final local decision as to which, if any, project
will be proposed for federal and state funding.
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FEB 2 1381
February 1, l?8l {
EPA
flegion I
1200 Sixth Avenue
Seattle, WA 93101
BW-,
Attention: Roger Mochnick V/S U|3
Dear Sir:
Ke are rushing this written comment to you so as not to miss the
February 2 deadline as we have nissed information on all public workshops
and heard only a bit of the public hearing January 21 in Seattle.
We strongly oppose any discharge of effluent to Puget Sound at the
Point Pulley (Three Tree Point) area. Our imiaediate reaction was just
keep it away from the Seahurst Paric outfall, but after investigation.
we believa any of the three Three Tree Point outfall sites would be
detrimental to the waters and beach at Seahurst Park and every private
beaziifront fro.- Thres Tree ?oint northward in nearby coves, not to mention
the harmful effect of such discharge to mainland beach an:l water south of
the Point, including Tacoma an! Cosnancficie.it Bay, where KQAA has recently
confirmed fis±i contaminatico. and Maury and Vashon Islands.
Alternative A-l to expand the existing Henton treatment plant and
increase the level of treatment to advanced secondary and continue to
discharge treated wastewater into the Creen/Ouwamish River would be our
preferred program or else piping effluent down the Duwnmish. This is
the loar.t costly of the alternatives, per your cost estijnates. Also
if the proposed dredging of the Cuwaiiish for ship traffic further up
t/r.? ri.v^r shoal'! occur, and we believe this is j;oi-i2 to occur when the
now Wesi S?st!l(? oridge is constructed, the additional water would then
be needed in the rivsr.
®
~Ke are totally against Metro crossing miles through an area
it doee not even -serve, aid draping effluent into Puget Sound uaters
off areas it also does not even serve.
Studies at affluent dispersion froa the West .Point outfall show
that in summer, effluent is present on tte beach (pages 2, 62-63, Puset
Sound Interim Studies, dispersion of Sfflaent froa the WesT. Point, Outfall,
Applied Physics Laboratory/University of Washington, February 1976, Final
Report. On page 2, 1,1 Sampling Flan, paragraph 2, Puget Sound Interin
Studies, Demersal Fishes Hear Metro Sewage Treatment Plants and in the
Dunarcich River, Fisheries Heraarch Institute, College of Fisheries,
University of Washington, Tinal Report, June, 1977, a save of the
sampling sites was justified "since studies by the Applied Physics
Laboratory (l?75) and Evans-Hamilton. Inc. (197'J, bad shown that
effluent from the (Vfest Point) outfall reached both the north and the
south beaches."
Since "no major impacts expected"1 on Puget Sound is written in
EPA1 s Metro Wastewater Kanagement/Sunnary Draft Environreent Ir.psct
Statement and has been re-stated at meetinss, aich as January 27, at
the Burien Southwest'Suburban Sewer District neeting, you must cor.d..-ier
the presence of effluent in su.-ET.er on the besch as not a najor impact.
When was the last time you and your family went svinm n.j; i.i effluent'.
Thousands of psopls swi.ii and play in Puget Sound along the beaches north
of Three Tree "Point, including Kins; County1 s Saahurat Park during the
siimnar.
The are.i north of Three Tree Point is cove shaped. We have
personally witnessed each .TU-nrcar the accumulation of a drift lino, of
dehrif that stays intact, from ptor.i to stoi-i ana slovlv drifts fro^.
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-3-
thousands Df feet out, to earning conpletely into and regaining on the
beach. The surface waters of this cove are very quiet during the summer
and any effluent that cane to the beach would stay in the area, thus
creating a build-up until some turbulancs (a storm) stirred the waters
again, weeks or months liter.
"During the late spring and sunnier, the possibility exists that
juvenile salmonids and othsr species which exploit the nearshore
environment around West Point nay be adversely affected by wastewater
entrained into nearshore shallow waters by inshore eddies" page 75, #3.
Puget Sound Inter-in Studies, Denersal Fishes Hear Metro Sewage Treatment
Plants and in the D-juardsh rtiver, Fisheries Research Institute, College
of Fisheries, University of Washing-ion, Final Report, June, 1977. We
maintain th'i sa^3 conditions would exist around the Seahurst Park area.
We eat the fish and crab caught in this area. We aren't willing to
take a chince on adversely affecting sea life in this area. Humanity
itself is in dagger when we contaminate the food cycle.
It does seem that something should be done to preserve fishes
and irr.m-ove water quality in the Duuamish, but not by dumping the
problem from one area (Duvamish) to create another problem area (Soubh
Pu£.-t Sound), '..'e urge yo-j to further treat sewage at the Renton plant
to advanced secondary (nitrification), alternative A-l.
Sincerely,
3r. ami Mrs. A. I. Moura
12801 Stanriring Lane S. W.
Seattle, A A
Response to A. I. Mourn Letter of February 1, 1981
1. See General Response Numbers 1 and 2.
2. See General Response Number 3.
3. See General Response Number 1. As to the West Point
effluent reaching beaches, the interim studies did report
instances when it appeared that West Point effluent, in very
dilute concentrations, had reached adjacent beaches. But
even in the event that diluted effluent does approach the
beach, no adverse impact to beneficial uses occurs.
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THE GIDEON KRAMER ASSOCIATES • 206 THIRD AVENUE SOUTH • SEATT1E WASHINGTON «)8104 • :'(»>•(.:! I-!X.7(.
February 3.,
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Attentions Roger Mochniok M/S 443
Response to Gideon and Ruth Kramer Letter of February 3, 1981
1. See General Response Number 2.
We are property owners on the South beach of
Point Pulley.
We have made a considerable financial comittment to
bring about an improvement in the water quality of
Puget Sound and particularly of our area, and are
ready to support any effort to improve the water
quality of our greater region which we assume is
the intent of Metro's Lake Washington/Green River
Basin program.
It is important to recognize that because of the
underwater ledge across Admiralty Passage, the lower
stratas of Puget Sound must be considered a closed
system. Non biodegradable materials that settle to
these lower stratea will accumulate and be permanently
retained in, Puget Sound.
The proposal to divert inadequatly processed effluent
to Puget Sound and especially to a Point Pulley outfall
is not acceptable to us.
We trust you value our continued support and that
your final decision will be consistant with your
declared concern for improved water quality for ALL
people of this area, including those of Point Pulley,
Tacoma.>aivmpia, and all of the residents of lower
PugsfSound.
Gideon" Kramer
2401 S.W. 172
Seattle, 98166
Ruth Kramer
':>'••••' i ' ."' :, 'i "u/ •
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KAPPA ALPHA THETA FRATERNITY
GRAND COUNCIL
i'
MRS KARL H KLOPFENSTCIN
37SO S W I 7 1ST ST
SEATTLE. WA 98166
FEB 9
February 5, 1981
EPA
Region X
1200 Sixth Avenue
Seattle, Washington 98101
ATTN: Roger Hochnick M/S
Response to Dinah Klopfenstein Letter of February 5, 1981
1. See General Response Number 14.
2. See Response Number 1 to Haas letter.
3. A number of alternative discharge locations were con-
sidered and evaluated in the Wastewater Management Plan and
EIS. After considering the various trade-offs among the
alternatives, discharge off Seahurst Park was recommended
in Metro's final plan.
Dear Mr. Kochnick,
This letter is to advise you that my husband and I are vehemently opposed to
your bringing any kind of sewage disposal plan to the Three Tree Point/Point Pulley
location.
We were able to attend your meeting which was held Tuesday, February 3rd and I
must agree with the lady from Vashon Island that your initial publications
were designed to gain as little attention as possible. In fact we did not
ever receive notification of meetings through the mail. I consider this a
typically, despicable approach of our bureaucracies of today. Fr. Fleming is
correct - You are looking for ' a cheap, quick fix".1 I hate being conned.
How Ketro can consider spoiling the South Sound, which does not have the right
currents, and making a move to harm the property values of thoseresidents in this
particular area is beyond me. I think it is dreadful that one can't purchase a
piece of property, maintain a home and pay continual increasing taxes without being
harrassed with the problems of the East Side sewerage. It is unbelievable that an
agency such as Netro has the power to make decisions which effect so many innocent
citizens. Let the East Side handle their own problems!
We do not want tunnel construction, easements nor a pump station of ANY KIND
in this area.1 This is a residential area - why don't you consider a pump
station on Hunts Point? On. E^ ,^i>r-,r "?tv< . .~v ^
I®
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February 12, 19fll
16303 Maplewild Ave. S.W»
Seattle, Washington 98166
Environmental Protection Agency
Region I M/S Uj3
1200 6th Avenue
Seattle, Washington 98101
Attn: Roger Mochnick
Gentlemen:
I have attended two of your neighborhood information meetings
wherein the proposed routing of the waste-water from the Renton
Valley Metro system is suggested to be dumped in the lower
Puget Sount area, south of Alki Point.
While I am sympathetic to the necessity of dispensing the
secondary treated sewage that accumulates in the Renton valley,
and that Puget Sound is a logical place to rapidly dilute
this waste water if placed in the sound at the proper point,
I am emphatically opposed to any plan that will allow the fall
out to flow into the south sound below Alki Point, by tidal
action, around Vashon Island before it finally flows North out
of the sound.
My reasons for these comments are:
1) The tidal action is very sluggish from Alti Point south to
Tacoma, whereas from Elliot Bay north, out of the sound,
the tidal flow is much more pronounced and regular.
2) The South Sound is burdened already with the S.W. Sewer
District, Normandy Park, Des Moines, Tacoma, and many other
smaller systems extending the Shelton-Olympia area to
Vashon Island.
3) The rapidly developing residential areas from Lynnwood to
Auburn which collect at Renton will put increasing demands for
run-off that I am not convinced has been accurately estimated
in -this initial study. Establishing an underground tunnel to
dump this water below Alti Point, based upon the inadequate
study and unknown volume of future sewage from the Renton
Valley, will only lead to a plea to increase the volume, or
build still another tunnel in the near future.
li) Very little is known about the geophysical status of the
underground structure of the soil, and the estimates for
constructing such tunnels may well be many times the projected
costs in this study. Underground rivers and sand deposits
can make such a project many times as expensive as constructing
a pipe -down the Duwamish River and directly out into Elliot
Hay where the sBwage can -move out of the .sound.
.,,,
-2-
5) The property values of the Seahurst Park, Three Tree Point
Point Pulley, Normandy Park, and Des Moines, would be materially
affected by a major sewer dump that is proposed in this study.
The beach areas would be continually suspect for being suitable
for water recreational activities.
6) To foist the economic problem of haying to charge a. tea more cents,
or even dollars, per residence to those dependent upon the Metro
sewage system, on either the residents of the South-Sound, or for
that matter, to burden the ecological structure of the entire lower
sound, is in itself'an expedient way to solve the problem. Why not
face up to the problem today and do it right?
7} Of all the alternatives proposed, the choice of the lower-sound
will have the most deliterious effect upon the people in general,
and upon the long range balance of the eco-systems of Puget Sound.
8) In my opinion man. should "Bite the bullet" today, and if necessary
construct disposal plants that will put the water back on the earth
in a pure state. It would seem that man can do anything he thinks
of, and it is time to put some thought to this problem rather than
take the easiest way out.
I, for one, will take every measure possible to resist any effort to
dump the Renton Valley sewage waste water in the lower-sound.
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Response to Myron B. Savage Letter of February 12, 1981
1. See General Response Number 1.
2. See General Response Number 2.
3. See Response Number 4 to Jeanne L. Snell letter.
4. See General Response Number 11.
5. See General Response Number 8.
6. The final plan recommended program was selected after
a careful consideration of impacts of various long-term
alternatives. Certain adverse impacts of the recommended
program are predicted in the Final EIS, and mitigation mea-
sures have been proposed to avoid or reduce these impacts.
The costs of making Renton effluent "pure" would make this
alternative economically infeasible, because the incremental
costs of removing the last pollutant concentrations in effluent
increase dramatically.
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Response to Beth Savage Letter of February 12, 1981
1. See General Response Numbers 1 and 2.
2. The temperature of Puget Sound at West Point vs. the
south sound is not expected to be a significant factor with
regard to effluent effects.
3. The significance of the differing widths of these channels
is not known. However, tidal currents are generally stronger
in the West Point area than near Three Tree Point. The Final
EIS has compared oceanographic conditions between Alki Point
and Three Tree Point {Chapter 6).
4. The question relates to wastewater flows from the North
Lake Washington and North Lake Sammamish basins and whether
these flows should continue to receive treatment at the West
Point treatment plant. As discussed on pages 54 and 55 of
the Final Plan, Metro intends to resolve this issue as it
finalizes its plans for the West Point treatment plant. If
the remaining capacity at the West Point treatment plant
is fully utilized it is technically possible to continue
to accept the North Lake Washington and North Lake Sammamish
flows. CSO control would not provide any additional dry
weather capacity at West Point. In terms of wet weather flow,
additional CSO control could be used to reduce the volume
and/or incidence of CSO's but would probably not provide
additional wet weather capacity.
5. NOAA charts show slower current velocities near Three
Tree Point than near Alki Point, as indicated in the Final
EIS (Chapter 6).
6. See General Response Number 1.
7. See General Response Number 8.
8. Metro's consulting engineer considers tunnelling under
the Burien area to be feasible.
9. This alternative has been evaluated in Metro's Final
Plan. It is more costly than either the' Alki or Seahurst
Park outfalls, would have extreme construction impacts, and
may not provide significant environmental benefits.
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15911 S.E. 177th Street
Renton, WA 9B055
15911 S.E. 177th Srreet
Rencon, Washington 98055
February 15, 1981
February 15, 1981
Roger K. Mochnick M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Mochnick:
Attached is
Attached is a copy of a letter sent also to Metro in
response to the Draft Plan and EIS for the Wastewater
Management Study for Lake Washington/Green River Basins.
Please accept this as my comments to the EIS also.
Sincerely,
Wayne J. E. Lamm
Enclosures
Ms. Gerry Larrance
Municipality of Metropolitan Seattle
Community Involvement
821 Second Avenue
Seattle, Washington 98104
Dear Ms. Larrance:
I thank Metro and EPA for this opportunity to make comments on the draft plan
and EIS for the Wastewater Management Study for Lake Washington/Green River Basins.
I realize the considerable effort that has been involved in preparing these studies,
by all parties, therefore I make the following comments to enhance this effort in
the final plan. I have served on the Citizen Advisory Committ ee that has reviewed
this study from the beginning. My views are expressed as a concerned citizen and
personally as an environmentalist,
GENERAL COMMENTS AND CONCERNS
Although this study includes only a part of the total area served by Metro, there
is a basic lack in explanation of how this plan and the facility improvements indicated
fit into the General Comprehensive Plan for wastewater management areawide. Many of
the decisions to be made in this study are influenced by areawide decisions such as
sludge disposal, closure of obsolete plants, CSO plans, limitations to the West Point
plant, and equitability in the rate structure. There is a recognized need to move
forward with expansion, to some degree, of the Renton plant but this should be con-
sidered as a part of the Metro overall wastewater management of the Puget Sound area.
I commend the decision of Metro in moving the effluent out of the Green/Duwamish
River and directly into Puget Sound. This can only enhance the water quality of this
valuable river. Furthermore, I totally support the strong position Metro has taken
in considering only the designated sewer area in its facility plans, thereby allowing
local land use areas to decide their own growth rate and density. The measures pro-
posed by Metro to insure on-site systems as a permanent waste treatment possibility
are steps in the right direction. r
SPECIFIC ISSUES AND CONCERNS
(A) How this study in general and each of the alternatives considered fit into
the areawide comprehensive plan of Metro should be an integral part of this document.
The interrelationship of various factors should be discussed in detail.
(B) Although sludge disposal is currently being examined in a separate study,
the lack of information makes consideration of several of the alternatives listed
difficult to assess. The final plan should address the effects of likely disposal
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- 3 -
methods on each of the alternatives. Impacts as to truck traffic, pipelines, land
application, plant facilities, and remoteness to application sites need at least be
•evaluated.
(C) The recommendations for Wastewater Management in currently Unsewered Areas
(p. 78-82 of the Draft Plan) represents an important program that may in the long run
do more to enhance water quality in the region than all of the expanded sewer facilities
planned. The importance of this program to succeed is sufficient to recommend that Eft
require written guarantees, from all agencies involved in the fulfillment of this
program, as to their commitment to carry out their responsibilities before any grant
money is given for the expansion of sewer facilities.
Particularly: (1) I would like a statement added to Section A. 1) (p. 79 Draft
Plan) since failure of community systems are potentially more disastrous than
individual on-site systems. "Community systems should be inspected by the regulating
agency at yearly intervals and legal responsibility for the long-term maintenance and
performance of the system be shown in writing by the builder/developer before approval
of such system is given." (2) Section C (p. 81 Draft Plan) For the long-term
financial protection of the person, who Is willing to consider alternative waste watei
technologies and make them work (such as dry systems), allowances should be made by
Metro and local sewer districts which do not force hook-up to a new sewer line if
sewers are deemed necessary to bail out neighboring failing systems.
Optimally I feel that Metro should push for water conservation andkdry systems
throughout the service area as fresh water becomes a limited commodity.
(D) Preferred Alternatives
Metro has Indicated in its Draft Plan that A3 (Ft. Pulley discharge) and AS (Alki
Ft. discharge) are the two preferred alternatives. Metro and EPA have stated that the
Alki Ft. discharge would be the better of the two from a water quality standpoint with I
its reduced residences time for effluent In the Sound. Does this water quality benefit!
justify the extra $78 million to discharge at Alki Ft.? I feel that it does in view I
of the fact that the real difference in cost is not near so great when taking into
account other areawide programs.
In the Preliminary Plan for this study (p. 25), the possibility of using the tunnel
along the Duwamish as a temporary solution to controlling storm water overflows (CSO)
was stated along with an estimated savings of $50-75 million over conventional control
methods. On Page 26, a $10 million savings is noted for the phasing out of the Alki
plant by including a reverse flow tunnel within the proposed Alki tunnel from the
Renton waste treatment plant. Furthermore, in the Draft Flan, the A-5 present worth
value is always overstated by $12 million (p. 73) since it includes a larger tunnel to
accomodate the Alki reverse flow tunnel. Yet another Indirect benefit is possible with
the A-5 alternative by sharing some construction cost with a proposed Duwamish treatment
plant (p. 27 of Preliminary Plan). No actual money figures could be given but the
potential for substantial savings is there.
For a true comparison between the two alternatives in the final plan, these
specific issues must be addressed:
(1) Comparison of alternatives for handling equal volumes of wastewater (I.e., I
Alki tunnel cost only for what would be necessary if it was the size of the Ft. Pulley
tunnel).
(2) Fig. 2-29 in Draft Plan show the following changes:
(a) Route D and Route Z: Gravity sewers-120 in.
(b) Tunnel-fully footnoted to explain the reason for the Increased size
and relation to stated cost.
(3) All associated benefits through CSO, plant closure, new plant construction I /£,
must be evaluated. A revised comparison of cost for A-3 and A-5 based on these | VS/
savings.
(4) An environmental statement detailing the short-term effects of const ruction llO)
along the Duwamish river and of all tunnels considered in the plan. '
(5) The most current data on currents, resident times, etc., In the Puget Sound
for all outflow locations. There should be included maps, charts and tables that the
general public can evaluate.
(E) Equity Issue
There Is a rising concern in the general public as to who is going to pay for new
facilities dictated by the growth in population. Will the new people .pay their share?
Will one area be burdened again with facility cost which do not serve them directly?
The Draft Plan has totally neglected this issue even though this concern has been
raised repeatedly at workshops and hearings. Again this points to the need for this
study to be viewed in respect to the areawide plan for wastewater control.
The equity issue Is complex and may require a complete study on itsv,wn,
authorized by the Metro Council. Regardless of this, the financial aspects of this pi,
should be presented in terms that will indicate sources of money and the benefactors
of facilities planned. I have listed only a few of the specific items and factors tha
need be presented in the final plan.
Specifics
(1) New facilities and Improvements should be separated by those necessary to
maintain present service versus those required by increased growth. Many factors woulc
need be considered in dealing with this issue, such as depreciation, replacement, commc
facilities, and areas served.
(2) Similarly, estimates, as to the,amount to Metro each category would contribute
should be presented. Since rates charged at present are all the same, categories must
Include groups throughout the aresv.-; '•- service area.' Comparison then should be made
as to services rendered and fees paid for people in each category.
(3) The incremental increase in sewer rates due to implementation of each alter-
native needs a much better explanation. Is it a mean of the rate increases over the
next 20 years? If so, is it expressed in present day value? How does this increase
occur over time? This rate increase for each alternative would be much better under-
stood from a graph showing the rate (present worth value) versus the next 20 years.
Major factors (i.e., phase I & II) affecting the rate level should be indicated on the
graph. Population estimates may also be valuable to plot.
13;
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(4) Evaluate several means of raising money for expansion besides the simple
rate increase (i.e., building permit fees, hook-up charges, developer fees, variable
rate structure, etc.). With the rising interest rates on bonds, Metro should consider
the <*dvantages of "upfront" charges in reducing total financing costs.
(F) Interim Measures
To reduce the impact on the Duwamish river, Metro should implement its cost
effective measures to reduce the load on the Renton plant until Phase I is complete.
West Pt. should be used to its fullest capacity. Even if the Redmond connection is
built by not activating it. A moratorium on new hook-ups and delaying extension of
Interceptors should also be imposed, if deemed necessary.
SUMMARY
The urgent need for the expansion of the Renton treatment plant is recognized but
the lack of necessary data being collected in ongoing studies (i.e., toxicant, sludge,
and Puget Sound water quality) makes major decisions premature. Many of the issues
raised in this study need to be considered in an areawide approach. I urge that Metro
and EPA resolve the issues of concern to the public in the final plan.
Sincerely,
Wayne J. E. Lamm
Response to Wayne J. E. Lamm Letter of February 15, 1981
1. The "preferred facility plan" for the Puget Sound treat-
ment plants (January 197^; was used to guide the Renton 201
study. Recently members of the Metro Council have indicated
an interest in restudying portions of the preferred facility
plan for the Puget Sound plants. In response to EPA's decision
on Metro's waiver application, Metro staff will finalize
the Puget Sound facility plans and EIS. At that time the
Metro Council will have the opportunity to reconsider prior
conclusions concerning the West Point system. Changes in
the recommended plan for West Point could impact the long
range program for the Renton treatment plant. But the near-
term need for Renton expansion to 72 MGD with solids processing
and effluent diversion is needed in any event. This issue
is discussed in greater detail in Chapter 3 of Metro's final
Facilities Plan.
2. See General Response Number 5.
3. EPA recognizes the importance of the recommendations
for improving the performance of on-site systems in the non-
sewer area. Not only will improved performance help protect
surface water and groundwater, it will also help prevent
unnecessary public expenditures for sewer systems. EPA is
formally recommending that Metro take every available action
to ensure that needed recommendations are implemented by
appropriate authorities. Specific decisions on which recom-
mendations will be most effective are the responsibility
of the local implementing agencies.
4. A management program is required prior to approval of
any community on-site system. The comprehensive management
program should require routine monitoring to assure that
the system functions properly. Routine maintenance is another
important element of the management program. The frequency
of inspection depends on the type of community system, waste
load projections, and on local soil conditions. The in-
spection schedule should be developed on a case-by-case basis
as part of the management program for a particular community
system.
Regarding local sewer hookup policies, the decision
rests with local sewerage agencies and also depends on the
hookup policies of the local health department. Current
policies do -require that residences hookup to adjacent sewer
lines.
5. See General Response Number 1. The Final EIS indicates
that no major water quality impacts are expected a-t either
dischar-ge location.
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6. See Response Number 7 to PSCOG letter of January 8,
1981. Also, see General Response Number 9.
7. See Response Number 21 to Puget Sound Water Quality
Committee letter. This change has been made in the final
plan and Final EIS.
8. See Response Number 21 to Puget Sound Water Quality
Committee letter. Also, see General Response Number 9.
9. See General Response Number 9.
10. Additional detail regarding the environmental impacts
of constructing the tunnel/outfall to Puget Sound has been
provided in the Final EIS, and additional mitigation measures
have been proposed.
11. See General Response Number 1.
12. See General Response Number 12.
13. See General Response Number 12.
14. See General Response Number 10. Also, see Response
Number 8 to City of Bellevue letter.
15. Metro has determined that sewer rate increases are an
essential means of repaying the revenue bonds which are sold
to finance the local share of projects.
16. See Response Number 9 to Citizens Committee for Clean
Water letter of February 16, 1981.
17. Although additional studies and decisions will be made
in the future that relate in some way to the Renton plant,
EPA believes that the results of these studies and decisions
will not affect the choice of an appropriate discharge loca-
tion for Renton effluent or the decision to expand the Renton
plant to 72 MGD capacity.
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(V)
130?5 138 Avanue SE
Renton, Washington 93055
February 16, 19B1
Mr. Roger t'ochnick M/S 1(1(5
Invlronrcental Evaluation Branch
United States environmental Protection Agency
Seattle, Wanhin^ton 91101
I appreciate this opportunity to express concerns about limitations I
find in the Draft Plan: V/astewater Management Study for the Lake Wash-
ington/Green River Basins.
Deficiencies exist in the following areas; (1) toxicant data and potential
impacts (2) sludgo content and sludge handling ramifications (3) relation-
• ship of the Senton facility to the Puget Sound plants (lj) analysis of
financial considerations and (5) the on-site recommendations.
Toxicants
Previous Ketro documents emphasize the extreme importance of the toxicant
study. Paraphrasing Kr. Neil Peterson's remarks made in August of 197?,
"Metro must have the results of the toxicant study before recommendations
on what configurations and treatment processes should be built in the next
10-?5 years." NOAA and your agrncy similarly point to the unknowns
relative to toxicants and their impact on the Sound.
We have no toxicant study yet «ie have a Penton facility plan - a plant
expansion to cost millions of dollars - Can we safely du-np wastewater from
Rpr.ton into th° Sound wh = n we haven't the data base about toxicants? What
treatment processes do we really nerd at Rrnton?
Slu-ire
Ketro acknowledges that sludge is the most serious residual waste problem
facing treatment facilities all over the country.
-Do v/e have the information necessary to a decision that places all sludge
process! n" at Renton? V/hat toxicants rrnai n in the sludge? Can we safely
contemplate land disposal? Are sludre contents appropriate to incineration?
V/e are one year away from results of the sludge study. How can we ignore
this lack of information when sludge handling will be one of the major system
changes at Renton?
a°latior.sM'o to the Puget Sound Plants
Metro is still waiting for a decision on secondary waiver, Metro consumers
are still waiting for a decision on a Duwanish facility. As I understand
th» Preferred Puget Sound Facility Plan, the centerpiece of the plan was a
D-jwamish facility, with other system changes dependent on that facility.
Here we are, charging ahead without a Duwamish facility but with all the
problems that that plant was supposed to solve-CSO and toxicants, primarily.
I didn't find any analysis of how having or not 'having'a Duwamish plant
would affect the location'of the outfall. Does the Alki outfall help or
hinder the CSO and toxicant probl-m? Can future construction
mitigated more by an Alki or Point Pulley outfall?
Conclusion
While the Renton decision is "late" in terms of capacity problems, it Is
too early in terms of Tiaving sufficient Information to make the long-term
decision which clearly serves the public interest.
It seems patently clear that the pressure is exerted by the land use
entities—by allowing system hook-ups they have forced l-'etro's hand
a hand that is half empty—no toxicant study, no sludge study, no Duwanish
decision, no waiver decision and no power to deny service hook-ups to a
system that is approaching overload and ie threathening water quality.
Does EPA have the power to order hook-up denial when degradation of the ,'5")
river is at stake? DOE? Or does it fall to citizen action?
Financial Considerations
.1 find financial aspects of the study incomplete and inadequate to an
•understanding of what the costs are for implementation of this plan.
Questions relative to financing and rate impacts:
Re: incremental increase due to im-olementation of the Puget Sound Facility
Plan. When would this increase take effect? How will this increase
escalate over time. Is it correct that this is a separate set amount" that
will go into effect with -or without the Renton facility?
For simplicity, I differentiate between what I call the current basic rate
(SI+.50) and the increase mentioned above.
How is the basic rate projected to increase over time? V/hat are the corapone
of the basic rate? V/hat amount goes to capital costs? '.'/hat amount to M & 0
What portion to bond amortization?
•Re: Bonds
'.Vhat is the limit on Metro's bonded indebtedness?
Is there an interest rate limit at which Metro's bonds can be sold.
What bond costs are anticipated froa this planned project?
When would bonds for this project be sold?
V/hen would rate increase tied to this project go into effect?
Re: Policy Issue of "'.Vho should pay?"
.- What array of funding possibilities were considered in addition to rate
increases for current and future rate payers?
Was consideration given to a water pollution tax? As stated this plan is
in direct reponse to capacity problems, which, if not solved will lead to
degradation of the river. Thus, it annea" we have a direct line cause and
effect relationship attributable to specific sources..
Would a two tier rate structure meet the demands of equity?
V/hat reduction in total costs would result. from requiring an "up-front"
fee on new connections?
On site Recommendations:
The section dealing with on-site system failure IB totally inane. What it
amounts to is^synopsis of the ignorance level of the people they asked about
septic tank systems. There is no hard data to substantiate their conclusion
of massive septic tank failure.,...! am not saying there is not septic tank
failure, I am only saying the Ketro data doesn't prove that there is a
significant problem.
(9)
10
-------
If such failure exists, isn't it Metro's obligation to recommend a
comprehensive rehabilitation and conversion project to bring such systems
into compliance or replace systems that will not work? Federal noney is
available, isn't it? There Just has to be an aggregating entity. Certalnl;
such a recommendation is Bore in keeplnr with a water quality concern than
advocating another layer of government (management systems) to keep watch
over septic systems eonstructpd on sails inappropriate to the task. Please
tell ae how periodic inspection will cure a system installed on land that
Is unsuitable for a drainfield?
This maaageoent system recommendation is symtonatlc of Metro's pervasive
emphasis on drainflelds as the accepted method of on-slte disposal. If
Metro believes the Soil Conservation Service figures that show $0% of the
land in King County has severe limitations for septic tank drainflelds and
they are serious about an effective, long-term reliability.quotient .for.. .
on-slt» systems, then a resoonslbilc recommendation has to be for some
other form of on-site disposal.
With mounting evidence that the sufficiency of doaestic water supply is
already in question, isn't It a paradox that the water quality agency
contlnuer to stress water-based systems?....systems based on pollution of
water of drlnkln? quality,,,,
Ketro should be emphatically recommending the phase out of water-based
systems unless they provide secondary treatment. Further, the on-site
recommendations should advocate non-hydraulic systems or non-absorption
systrms, or systems dedicated to re-use of water.
Ketro should stipulate that State and County mandatory book-up requirements
be abolished so that property owners with functioning conventional systems
or Innovative systems are not financially penalized.
I would be denying my true convictions if I failed to cite this plan as
totally lacking a futuristic view. While this plan is the cheapest one
they could fit into their pre-concelved notion, I feel strongly that future
generations are not nerved by a centralized, hi tech, hi energy, hi chemical
hardware system which dumps into any body of water. 'He need adequate on-
sit
-------
10. EPA recognizes the importance of the recommendations
for improving the performance of on-site systems in the non-
sewer area. Not only will improved performance help protect
surface water and groundwater, it will also help prevent
unnecessary public expenditures for sewer systems. EPA is
formally recommending that Metro take every available action
to ensure that needed recommendations are implemented by
appropriate authorities. Specific decisions on which recom-
mendations will be most effective are the responsibility
of the local implementing agencies.
11. Reuse concepts currently incorporated in the recommended
facilities plan include recovery of methane gas from sewage
sludge, and proposed land application and composting of digested
sludge. Regarding decentralization, the final plan recommended
program leaves open the option of building a Kenmore plant
to treat flows from the north part of the study area. Six
additional small decentralized plants using land application
were evaluated in the draft plan and EIS, but the potential
land use benefits of such plants did not appear to justify
the increased costs involved, and little public support was
expressed for this concept. Large-scale land application
of Renton effluent appears to be infeasible because sufficient
acreage of suitable close-in open space or agricultural land
does not exist.
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EHvlronnentHl Protection Aganoy
Region X, 1COO Sixth Avanua
Seattle, Washington 98101
2651 S. rt. 164th Place
Seattle, Washington 98166
February le, 19aj._
PJls
•7 PA
*-i n
T«o
February 16, 11-S1
At tentIon;
Rogar Moohnlok
M/S 443
Dear Mr. tiochnlck:
.
Subject: Environmental ImpocBBANCH
Statement: 'A'astenater Kanage-
ment Plan for the Lake Wash-
ington/Green Rlvor Easins
This letter is in response to the subject Environmental Impact
Statement Draft and the Municipality of Metropolitan Seattle Draft
Plpn. n'e live near Burien and will address herein problems we
havs encountered -ith respect to Metro's Alternative A-3,
A. Procedures followed by Metro leading to its recommendation
of A-?, Point Pulley (hereinaftsr called Three Tree Point), do not
appear to have followed the spirit or requirements of the law.
The procedures in question are as follows:
1. Membership on the Renton 201 Citizens ' Advisory
Comr.ittee does not appear to have proper representation by citizens
from the Southwest area. We believe that only one person from our
area was on that committee and that person was not replaced when I
she felt sha had to rasign. Of 19 members, one or none is obviously)
-inadequate for a greatly impacted area such as the Southwest.
iietro 's own words in the Draft Plan, page 157, 2nd
paragraph, state: "Committee membership .vas approved by EPA and
consists of private citizens, public officials and individuals -ve-
of the full draft plan or the full EIS. .Ve had to request thst
they try to get them. The Draft EIS, ?£ge 2"2, stetes th=-t "tr.
document has been for.varded to public librerics i;i the itu
so that other concerned residents csn revia.i the potential
of the project. Were we not to be considered as concerned
residents?
cy erc-j
'imoect
If EPA ..era to reply that meeting notifications,
libraries, etc., ..ere provided for -the study &ree only (..hlch
snoeerp. to be aiinly tf-e esse), this would not sat isf Jotor 5 IT
answer our contention tnst the South.vest area has been left out
of the planning process.
7. ?l6nse .-iota EPA 's statement on the lv;St -?ce of
the Sum.T.ary Drsft EI3: "Opportunities for Public Involvr-:.i3:it .
"Metro 's proposed '.iHSteaater i-Iar-'i^siaent ?Isn .vlll hcve irnporta it
f pr-j'eachlna effects on 'he futuro of Uio' r-j sic =•.-><• ? -nl the
environniint of the Lake wV.shiagt ai/Gr-jen River Bi:::in st-.i^- area.'
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EPA
Page Three
Feb. 1C, li»61
'.Vhet at out "important and far-reaching effects on the future of
residents end the d;ivir oruient " of the South'.est ures, e.g. E'Jrien,
Three Tret Poi.it, S<:urv:rst, Seohurst park, l;or::iondy Park, Des ,.;oi.i*s,
Fecaral .iay, other southwest co.i:,,.unlt ie s , Vasho.i, i.aury Island j..c
t:i- .vOEt Eh->re of Coivos Pcssare? pecpij i:; th-se communities raay
or nay not live o., the shoreline, but they do go 1.0 the teaches, snin
Ln the Soi;.,d, co out in boosts, fish, dig cla-as, gooay ducks, etc.
tThey in effect have been denied the opportu.-iitit s aentlo.-iKd shove.
8. The title of the Draft Plan: "'.Vasterfnter Management
Study, Lr.ke Cashing ton/Green River Essino gives no clue to its connec-
tion with concerns about Puget Sound and is therefore misleading.
If Southwsst residents saw c meeting notice with that title it >'.ould
have little meaning.
9. An article ir. the Seattle Times on December ?2, 1980,
page Ef, cannot be sited by ;.!otro as publicity on the Plan. Reference
was rr.sde at tne be^lnr.lnj of tho article to Seacresi. Pcr'.c and Point
Pulley. The oniy Seecrsst we k;io,v of was a .Vest Seattle raarina on
Elliott Fay. Point Pulley is not i. r.arie known or used in this area
and i; :ut even the legal nsr.e . The ncne *as ao little used that
it *as legally changed in 1930. In the same article inf or.nat ion
ere listed for Al'^i, RelLsvue, downtown Seattle
and Kent
but not for Eurlen. Repeated onissions such as this make it difft-
cult to believe they .vere all inadvertent.
vVa have seen only one other article in the Seattle
Times that related Metro's plans to our area. It described what
occurred at the public Hearing; this ..as obviously too late to be
t notification of the hearing. The Highline Tiir.es carried a notice
of tho Public Hearings on page one; unfortunately this was on the
snae day es the hearing - hardly a;:.pla notice and in uar.y cases
uselsss for those tvho got this newspaper by mail the following day.
Actually, the rUgnliiis Tir.es is distributed to only a fraction of
residents, so coversge in the Times and P. I. is important. The
P. I. did publish an editorial rscorrraeadiag the Alki location.
10. Persons who attended the Highline Council/Metro meet-
ing on February ?., 1SB1 have pointed out that Metro did not state
thct consents could be .-race to EPA by February 17. Unfortunately
the Sugary Draft EIS that .ves passed out by Metro did not have a
corrected date for submitting coments. Ketro should have been
atle to cror.a out the ? and .vrite in a 17 on each one. Since
Fehrufiry 2 had already passed, people could not be expected to know
tb>t.» thty cTJid still co.-r.ment to EPA. At least one person thought
th'.t corr.-ents rr.ace at the meeting would be suificisnt. However,
alnct; ErA rfas not present at the meeting (*e understand that Metro
dl-i not invite EPA until about Ij cays before the meeting) cora-r.ents
to 2PA a? re not possible.
11. TheVvls contains a list of soproximat ely P66 persons
arid orrnnizEtions ,\ho recaived copies of the full Draft EIS. Of these
'.he Burien ares, ons p-erson in Federal
hp.d tccresses in
oni" ' c^o
.Vry, one s-vver district near Burien, one newaoaper in Des I.'oines,
or.? t*o organizet io.-is .rere in Taco;r.s. Conspicuously not on the list
EPA
Page Four
Feb. 16, 1961
are: The Burien Chamber of Commerce, Highline Community Council,
The Highline Times, Seahurst Community Club, Three Tree Point Club,
Highline Recreation Council, City of Ilormandy Park, Norca.-.dy Park
Community Club, Hurstwood Community Club, City of Des toln&a and
many others to the south. How could these organizat ior.s have been
Isft out when the liat of ?66 hcs many similar organizations ell
over tf.f- greater Seattle area? Also, the number of individuals in
the Southwest who received the £13 is way out of proportion - that
iSj far less - than for Ren tor., Bellevuu, etc. This constitutes a
gloring omission. Who is responsible - EPA or Ketro?
1?. Anile we think we have some understanding of tho
involvement of the EPA es established by law and regulstion, *e
wonder if th3 EIS draft "as actually prepared by Lietro. The irLores-
siJn is that the EPA arid Metro are v.orking closely together. Perhaps
they ere and feel that this is beneficial. Ho*evcr , v,e wonder hov;
the EPA can then remain unbiased and detached enough to rneke deci-
sions that are supposed («e belisve) to promote envlron.-ner.tsl pro-
tection. \Vhat are the la.vs regarding this matter end are E?J, and
Metro following them carefully? (See attached page A-4 of the
Hlghlins Times.) -
13. We question Metro's Comru.iity Relations Planner's
statement that citizens in the Burien/Three Tree Point arsa /;ere
given adequate notice of the Draft Plan, etc. The statement
that all voters *ho voted in our area in the November 19SO election
were mailed a letter froc i.ietro should be proven or retracted. t.'o
one AB know, and v.e have asked many, received such e letter.
i..rs. Katthefts asked the planner early this month to pleese find out
*het happened but has received no answer. Also, the statement at
the Burien workshop meeting that letters .vare send to Metro users
in mail zones 98146 end £8156 was a.et with spontaneous laughter,
since probably very few persona in this ersa, If any, tre i.ietro
ussrs. (This point should be especially noted: citizens of this
area ere not Mstro users.)
14. We recognize that an oversight or t*o understandably
can occur. However, the numerous procedural omissions and errors
mentioned above constitute a huge gap in the public involvement
orocess. We do not think Metro can redress this wrong at this
late date. Therefore EPA should reject Metro's choice of th:
tunnel and outfall to the Seahurst/Three Tree Point sites for this
reason arid for the other sound environmental reasons that fire being
submitted to EPA by the se.ver districts, governmental entities,
c onur.uriity groups and citizens. If EPA does not do this and Metro
persists, then' we request that a ne,. £01 study of the South Sound
area of i.npnct including Vnsh-m/ulsury and Colvos Passage east shore-
line, afflin because of tho numerous procedural omissio.is e:ic errors
mentioned above.
B. Follo*ing ere our comments *itr. respect to the Three Tree
Poi/,t sites:
1. We fnv :- tertiary treatment *ith all its attendant
benefits. ,¥e kno* Metro has considered this ar.d
rejectee it for an aoc&rent quick fix that could have
disastrous consequence; in the future.
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EPA
Page Five
Feb. 16, 1981.
EPA
Page Six
Feb. 16, 1581
2. Although tertiary treatment la ah attainable goal In
this age of modern technology, If Metro cannot see Itself able to
accomplish this, we feel that f. pipe from the mouth of the Duwamlsh
River into Elliott Bay should be a subject of further study. In
fsct a pipe all the Jiay fro-i Renton would avoid a lot of problems.
Alternative B-l makes sense when one contemplates the really
unpalntable idea of bringing sewage all the way to Renton from as
far aaay as Snohomish County. It is only logical that a plant be
built to serve northeast King County.
3. Is EPA aware that tho Lakehaven Sewer District is not
in compliance with the NPDES permit? This should be one of the
factors looked '-at when considering the Three Tree Point area outfall.
4. We call your attention to "Information Paper, Toxicants,'
undated, apparently printed by Metro, Table 2, a copy of which is
attached: ^Priority pollutant Analyses, May 17-19,'1978, Metro
Treatment Plant .Vastewatsrs." Please note that Renton effluent column
R shows five Volatile Grganlcs Indicating a.h.e. (avoid human exposure).
Also again see column R where at least three Volatile Organics apparently
exceeded standards. Presumably Metro can provide the complete paper.
Are these concentrations in Reriton effluent still about the same?
5. The EIS Draft is deficient because it does not address
the effect of the combined effluent from the sewer districts in the
South.vest area of an expected 200 million gallons per day and Metro 's
effluent of 100 million gallons per day. This concentration of 300
million gallons per day would be going through Colvos passage where
the volume of jater narrows to about one-third of the volume of
watsr between Vashon Island and Three Tree Point. What is the depth
of the most shallow point where the effluent would flow in that
passage and what would be the effect at that poiat? Independent
studies should be made of the impact in Colvos Passage before any
Three Tree Point decision is made.
6. Metro's large drawings of cubes being shown to the
public and to its ".Vater Quality Committee (and soon to be shown to
the Metro Council) show only the ratio of the volume of Renton
Plant's efflueat(as it comes out of the pipe into Puget Sound water)
to the volume of water adjacent to the outfall. However, Metro
does riot acknowledge by a similar large drawing ho* the cubes are
changed after the effluent enters Colvos Passage. The missing
drawing would show a cube about three times as large for sewege
volume and a cube about one-fourth as large for the adjacent water.
And how ivould these cubes compare if you take into account the
fact thst one fourth (25j?i) of the water in Colvos Passage heading
north actually go^s arouad North Vashon and heads South again.'.'?
If Metro insists on continuing to show the first drawing, it should
ba required, to be fair, to show a secjnd drawing of the same type
representing the water volumes in Colvos Passage (and well into it).
(Alyn Duxbury has shown with the Puget Sound Hydraulic Models that
?.i% of the watir in Colvos goes around again. ' Consequences of this
factor must be considered; the cumulative effect could be alarming.)
7. Alyn Duxbury of the University of Washington Is Assistant
Director for Me* Programs for the Washington Sen Grant Program. The
Hlghllne Times (see attached) quotes him as saying he thinks South
Sound discharge "Is one of the least preferable options. "If you
want to put something in Puget Sound, lllce ae*age, and you *ant to
utilize nature, you jant to put it in a place where It gets the ..idest
possible dispersion. "If you want to do best by nature, put it where
It disperses faster. ' In view of Duxbury's position and qualifications
these statements of his should carry considerable weight In EPA 's
deliberations.
8. Metro is looking primarily at costs. We hope.that the
EPA fully realizes its responsibility to protect the environment.
Possible future environmental coats should not be inflicted on all
the people, wherever they live, who regard Puget Sound as a unique
national treasure to be protected from unnecessary exposure to pollu-
tants whose true effect over time is unknown. (Ketro admits that it
is exceeding its limits in the Duwamish right now; this could happen
to Puget Sound.)
It should riot be required of citizens like us who are
not even Metro users to have to prove to Hr. Lampe that spending
an extra estimated one hundred million dollars (inflated figure)
Is worth not'choosing the Three Tree Point locations. Metro's
answers to citizens attempts to do this go along the lines of "ffe
don't see any problem with that," and "No, that is not a factor,"
and on and on. Metro has placed some of their effluent in the
sound and then has said: '"'Ho couldn't find it." We thij.k when
100 to 3OO million gallons a day are pouring into the south.sound,
depending on where you are looking, thnt it will be fairly easy
for Metro to find it, eapeclally in Colvos passage, but probably
also right off Three Tree Point when the current is slo*.
Metro seems to be afraid of adding svan & few dollars
a month for a valuable service. (Ci-ty Light has no qualms.) As &
result, Metro is lendng w«ight to the old adcage of penny-wise and
pound-foolish. Those who hav» contributed to the need for added
sewer facilities should be expected to pay for that service. To
accommodats tham at the expense (environmental) of many others ty
•looking for the cheapest way is unfair.
C. This letter has shown thnt the Southwest area has Veen
neglected in the planning process and that Metro has not provided
adequate information on impacts to be expected on sewar districts,
people, communities, water quality, saa life, etc. If iletro is
allowed to prevt.j.j. in this matter, EPA will not have followed its
mandate for fairness and environmental responsibility.
Sincerely,
Enclosures
Page A-4, Highllne Times
.Tnbl» 2, Priority Polluttnt Analysts
(10)
P«\
Mr. and Mrs. Ple-rrr. Katthews
-------
Encl.
P i! iirhnili
— :§ °^ |!s=.?2|^?;
Sit 51
_ S
ffs)
/*37 ~y
1
<"^4 55
OS?
1
—
Tra
<:L
19
RB
-j&Z
12?
:r~*
Tra
9
q -.
2 mg/1
30
jL.h.e.
a.h.e..
4.6
500
a.h.e,. (14)c
100
25
a.h.e. !25)c
0 . U 3
1.0
1.4
0.3 total
0.05
a.h.e. C2S)C
0.5
aDetection limit = 1 ppb, Tr = 0.1 ppb
"a.h.e.." = Avoid human exposure
Tentative standards in parentheses are. limits for aqua
aquatic protection
Source: HPi = West Point influent-. May 18 and 19
WP: - West ?oint effluent, Mny 13 and 19
HP2 = West Point'effluent, May 17 and 18
R = Renton effluent, Kay 13 and 19
RB = Rich.-nond Beach effluent. May 18 and 19
-------
Response to Pierre and Vivian Mathews Letter of February
16, 1981
1. See General Response Number 14.
2. The questions were not designed to be leading. The
questions were designed to elicit public comment on the pre-
liminary plan. Several of the questions were in the form
of a statement followed by a request for agreement or dis-
agreement. In all cases, room for additional comment was
provided. These questions were not intended nor were they
used to rate public opinion in a statistical manner. Rather,
they were used to determine which issues were of concern
to the public and to identify any new issues which had not
been previously considered.
3. The "distribution list" printed in the Draft EIS was
not the actual mailing list for the document. It was based
on an erroneous Metro computer printout, which was not dis-
covered until after printing. Summaries of the EIS were
mailed with summaries of the draft plan to persons on Metro
mailing lists residing near the East Passage area. EISs
and summaries were also available at public meetings held
in West Seattle, Burien, Highline, and Vashon Island.
4. See General Response Number 13.
5. Advanced wastewater treatment (AWT) is seldom used for
ocean discharge of municipal wastewater because secondary
treatment removes a significant portion of the pollutant
load. The Final EIS predicts no major water quality problems
would occur with a secondary effluent discharge off Seahurst
Park, and given this finding, there is little rationale for
installing AWT with an ocean discharge. With a continued
Green/DuwamisTi River discharge, nitrification of effluent
(a type of AWT) was evaluated in facilities planning, and
it was concluded that nitrification would create reliability
problems and would still not eliminate risks to the river's
fishery. The effluent might be made still less threatening
to aquatic life through implementation of additional AWT
processes, but the costs and energy requirements of such
alternatives would increase substantially.
6. An Elliott Bay discharge was considered and found not
to be acceptable from a water quality standpoint. Alter-
native B-l involves continued discharge to the Duwamish River,
which is not favored by water quality and fisheries agencies.
The present plan does not foreclose the option of constructing
a Kenmore plant in the future.
7. There is no apparent relationship between the Lakehaven
Sewer District's effluent quality and the decision to dis-
charge off Seahurst Park.
8. The values in Table 2 for the Renton plant discharge
were based on the analysis of only one 24-hour sample. An
extensive toxicant study now underway at Metro is expected
to yield more detailed and reliable estimates of the sources,
concentrations, and fate of priority pollutants present
in the Renton treatment plant influence and effluent.
9. This deficiency was addressed in the Final EIS (Chapter 6)
Metro has indicated the total dilution of all effluent would
be about 1,500:1, a level which will not affect beneficial
uses in Colvos Passage. The depth of the most shallow area
across Colvos Passage is about 200 feet, near the south
entrance. See General Response Number 2.
10. Alki Point does appear to be a better location in terms
of rapid effluent dispersal.
11. EPA regulations for facilities planning require that
the most cost-effective alternative be selected. This incor-
porates considerations of the benefits to be achieved with
each alternative. Future environmental costs would be incurred
with each of the alternatives, including the no-project alter-
native, so the question is really one of balancing the costs,
environmental improvements, and adverse environmental impacts
of each alternative.
-------
FEB 20 19ft
ENVIRONMENTAL EVALUATION
September 16, 1981
Mr. Roger Mochrn'ck
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seottle, WA 98101
Rep Expansion of Renton Treatment Plant (Metro)
Dear Mr. Mochnick:
Be advised that we feel there are too many unanswered questions concerning the
proposed expansion of the Renton treatment facility of Metro. I believe the
expansion should be held up until those answers are obtained.
I understand one of the problems that is beino studied is sludge in the system.
Why not wait for the expansion to determine the possible solutions to such
sludge.
We worry also about toxicants getting into Puget Sound. Has that problan
been solved? Isn't there a way of handling the problem without dumping into
the Sound? What about inland counties or States that have no body of water
into which they can dump sewage/waste albeit treated waste? Why can't you
or Metro propose a dumping ground other than our beautiful Puget Sound?
Also, what about the costs of expansion? How will they be handled? Will
current ratepayers have to start paying now for expansion of facilities when
the present facilities can handle the waste of such current ratepayers?
What is the forecast of costs for this giant monstrosity on a per ratepayer
basis in, say, 1990?
Why do the "authorities" proposing this project suggest only ONE plant?
Shouldn't there be smaller treatment plants in other areas? I understand that,
at present, waste is piped all the way from Bellevue and beyond in order to
get to the plant west of Renton. It would seem to me that, if the "authorities"
were interested in the human population, they would propose dispersal of the
treatment centers in order to avoid something happening to a single facility
in one place. What would happen if, say, there was a large earthquake that
disrupted the treatment plant and/or some of the major lines near Renton's low-
lying valley? It seems to me that the health hazard would be too much to
imagine.
®
®
I would also like to PoinJnPyJ tnat current ratepayers must be given some
exemption for any expansions We don't benefit from such expansion — only future
developments do. (Municipalities can exempt residents/taxpayers from certain
assessments when residents/taxpayers receive no benefits or have other beneficial
interest.)
Versie and Warren Vaupe.l
400 Cedar Avenue S.
Renton, WA 98055
Response to Versie and Warren Vaupel Letter of September
16, 1980
1. See General Response Number 5.
2. There is no feasible alternative to Renton effluent
reaching Puget Sound (whether the disposal be direct off
Seahurst Park or Alki Point, or indirect, via the Duwamish
River). Other inland areas generally dispose of treated
sewage to lakes, rivers, or to the groundwater. Many of
these receiving waters are used for drinking water supply
or other beneficial uses. It is preferable to dispose
wastewater to saltwater because of its greater ability to
disperse effluent. Toxicant problems related to Metro's
waste discharge are being studied in Metro's ongoing toxicant
study.
3. See General Response Numbers 10 and 12.
4. At this time, Metro considers the advantages of a cen-
tralized system to outweigh the disadvantages mentioned. How-
ever, the option remains to construct a Kenmore facility
at a future time.
5. See General Response Number 12.
-------
LESLIE P. SUSSMAN
1 North Stadium Way,"6
Tacoma, Washington 98403
February 18, 1981
Response to Leslie P. Suaaman Letter of February 18, 1981
1. See General Response Number 1.
Mr. Craig Partridge
EPA-1200-6th Avenue
MS 443
SeatUe, Washington 98101
Dear Mr. Partcidge:
This letter Is to protect agatnstjhe alternative plan A3 which involves the
dumping of affluent in the three point area.
We are concerned that this will contaminate the sound area especially the
Gold Beach Vashon Island. We trust that you will not proceed with these
programs and plans.
'Leslie P. Sussman
LPS:lm
FEB 10 1981
ENVIRONMENTAL EVW.UMION
fJflAKCH
-------
-------
Response to Horace Parker Letter of February 18, 1981
1. See General Response Number 1.
2. Various alternatives for upgrading treatment at the
Renton plant and continuing discharge to the Green/Duwamish
River were evaluated as part of the planning and environ-
mental assessment process. The final plan recommended pro-
gram was determined to _be superior to these alternatives
from both cost-effectiveness and environmental impact stand-
points.
3. There is presently no indication that long-term environ-
mental costs would in fact be lower at Alki Point.
-------
..eti'c
- 2 -
i ebruory 16,
FEB i s 1381
EVALUATION
WAhCK
• ebruary 16, !>...'" I
»,etro -ewer iMstrict
''21 Jeconj Avenue
oeattlo, .'aahin.-.tori 9310^
Attm Ceraldine l.arranco
Community Involveiaent ->pecialist
r(e i ./astewater i..ana.\;ement Study for Lake Washington/
Ureen River Basing also known as Henton 201 Jtudy
Lientlemen i
Your above Man is incomprehensible to a citizen who has always felt
government agencies should be held accountable for their actions and that
the populace in the areas affected by such plana must be properly notified
and informed of proposed i/overnnental decisions. ,ie in the southern ^ound
communities were not.
Lelow are some questions I feel need answered.
1. ..hy have you discounted the Elliott Ltay location for the Renton
sewage outfall location? There is already a pipeline ri^ht-of-way from the
"enton treatment plant to lilliott bay, correct? It muat to cheaper to put
a lar,;er pipe where the existing pipeline right-of-way is and extend it out
into the Jound beyond the Bay versus tunneling down 750 feet and across to
Three Tree loint purchasing all the ri:5ht-of-way8 in its path.
2. .Jhy are you continuing to state that there is no effect one mile
froTi any of letro's outfall locations when last wec'l:'d 1 .1. broupjit out
that the coliform levels along the beaches within the one-mile ranee of thel
I.ietro outfalls are much higher thaf\ adjacent beaches?
J. isn't it true that if you f,o ahead with your Three Tree Joint
sewage outfall location the i-.etro customers will face a three-fold rate
increase?
'i. ..'hy would you deliberately misstate the capacity of the future
outfall pip&lir.c ao- 140 million i'allona a day when it is actually planned
to have a 340 ..i.illion r:dllons-£-aav canaoitv?
<>. liow can an a.-.ency lawfully choose to dump effluent froi.i a hu,',e
metropolitan area into an area that has its own separate sewer districts
and is not covered by metro's services?
6. /hat rirht doe:s .uetro have to discharge in an area of the Sound
which is known to have a slavish water exchange rate and has recently lear
more of another pollution problem in Commencement day? There are other
metropolitan areas in the southern -iound who haven't an alternative but
./.etro has many more logical alternatives in areas where the effluent will
have a quicker path to the .open ocean.
?. Jill the enclosed petitions with 700+siGnatures showing the
objections of v/ashon and waury Islanders to the Three Tree : oint outfall
area have any bearing on the final outfall location decision?
b. Joes Uetro serve the people or only itnclf?
(i.xa. ) Jeanne 1. Unoll
Gold Deach, i>.aury Island
lit. 1 Cox 210
Burton, i-Jaahington 58013
(1) 463-3053
Attn: Crairl artrid^e
Avenue i../b 4^3
led
Seattle, ;'ashinc;ton
Editor, Vashori !-.aury Island
editor. lil:;ta..l.:ii Tl...
-------
Response to Jeanne L. Snell Letter of February 16, 1981
1. Capital cost for the Seahurst tunnel is 102.2 million.
Capital cost for the West Duwamish gravity sewer is 139.8
million. In addition, Elliott Bay is not considered &
desirable location for an outfall.
2. See General Response Number 1.
3. See General Response Number 10.
4. The ultimate capacity of the Renton treatment plant
is 144 MGD. The capacity of the tunnel is designed for a
maximum of 144 MGD of effluent plus peak storm flow up to
325 MGD. Since increases in average effluent flow above
144 MGD would take up tunnel capacity needed for peak flows,
effluent flows beyond 144 MGD are not planned for the tunnel.
If future service area growth results in waste loads exceeding
144 MGD, planning and decisions would be required for new
treatment facilities and new disposal alternatives.
5. See Response Number 1 to City of Normandy Park letter.
6. See General Response Number 1.
7. EPA is required to carefully consider citizen comments
in all decisions having significant environmental impact.
EPA is required to weigh public comments along with the
requirements of law, and with factual information bearing
on a decision. Different segments of the public often express
different preferences. Although citizen comments are not
the only consideration in EPA decisions, we hope we do reach
better decisions by considering public concerns.
-------
s.r.A.
- 2 -
February 1?, 198!
February 1?, 19P>1
2. 1 . A.
1200 Ji::th Avenue, "/S
Seattle, :Jn. 98101
Attm Craig Partridge
Re: ;.ctro's Jastewater management Study for Ia!ce 'Jashington/
Orson Rivor Basins also >nown as Renton 201 Study _
Gentlenen:
Enclosed arc additional petitions fron Vashon and l.Iaury Island Residents
re.-isterin~ their opposition to the A- 3 alternative to the above study.
"ho'.-e arn -v;>pro:;i.:iately 70 ^signatures on today's petitions and addaJ to the
7CC'T su'x.iitt jj to icri Larrunce of Metro totals qOO or more.
I would. li?.s to than'.', lie. Craig I-artridge for his attendancs and
participation, at Vashon-tlaury Island's CoiTuunity Council meeting last
ni.^t and depress ijy regrets" that there wasn't i.iore tine available for
your presentation and our coi.L.ients.
AS I triad to state last night, the islands were not properly notified
ir. a ti;.iely fashon. I as an individual did all of the informing that
v;as done. .es, the plans were sent to the Seachcouber and the Community
Council but they were sent out durinj tlie Christmas season with no
ii.dic~t.ioa that" the plan involve! cur area and uost cf the people either
ti.'.-j": the:.-, a'vay immediately or put the;.] in their already busy "info" stac1*:
..• i.";for ::atior/re-arii:-g the plan Mas supplied, by a friend in the Three
"roc .ci'.'.t u'-'ea Mho was inforjieJ in ail intarviev; by a reporter of the
..i.lili.ia Ci:.ie3.
I LJI ! ..ia:-y nor:= here feel that the I'lan v/as Meant to be slipped by the
uni':~for.aa3 public and quietly brought to fruition before any objections
co"J 5 b3 raiofed. "he reason for thssfi feelings is that . everyons I have
cor.taotcl ir. the 'Jouthern 3ound Co.a.aunities including all of the najor
nj-.'jpcpsrs havo not !:nov/n ajeut the concequsnees of or even of the study.
I :iu"e not taj.er. on t>.ij cause lijhtly. I have attended meetings, done
lotj is roaii.-.^ of the full plan and 2i"j', tallied to i'C.\ as \vsll as various
oc.^u:\j^ra.;!.3r; and attenied ..ilyn Ju;
-------
:-..?!- :.ivl Avenue •
Battle. ..'ashin.rtoji 981C':
.iTTI1 1 'loruliilne I ur^nco
Gi..;.v .-.unity In\ '..Ive.noit Specialist
IV. i;.2: .'j'jtu'vutiT Manage uunt JtuJy for Lalce 'Jashin.-jton/
Green River Uajins alao '.mown as Renton 201 Study
'..'c. the undersigned residents of Vaahon and i.aury Islands, hereby
oppcne the \-J alternative to the ahove study due to the proposal that "the
effluent be introduced to the Sound at or near T't. Pulley, comraonly known as
Three ^ree l-o5.nt. . '.Je feel that it will have a detrimental effect on a creater
area of the Jound than the other more northern alternatives due to the division
of tidal flow in the Ft. Pulley area. This tidal flow could mean that the
effluent would travel as far as The Narrows and up Colvos Passage before
raovir.3 to the open ocean. \le wish our signatures to become part of the public
record in opposition to Alternative A-3-
*
Address
(1 rinted and sined)
D O.
°t ^Q 1
Response to Jeanne L. Snell Letter and Petition of February 17, 1981
1. See General Response Number 14.
2. See General Response Number 1.
3. The EIS attempts to describe the environmental impacts
of the alternatives as definitively as possible, but certain
findings are qualified where they are tentative or uncertain.
EPA does not claim that pertect "knowledge exists regarding
impacts of the alternatives, but believes sufficient knowledge
does exist to allow an informed decision. Regarding the
Kenmore plant, the final plan recommended program leaves
open the option of building a Kenmore plant in the future,
since it defers the decision regarding where to treat flows
from the north part of the study
V-
(NOTE; Approximately 700 signatures were received by EPA
on this petition.)
-------
2745 SW 156th Street
Seattle, Washington 98166 -.
February 17,1981
ID
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Saattle, Washington 98101
ATTN: Mr. Roger K. Mochnick M/S 433
REF: EIS 4 201 Draft Study for Wastewater Management of Lake Washington/Green
River Basins—Seattle Metro's Renton Study Area
Dear Mr. Mochnick:
I am concerned with the logic of what appears to ba a choice of the most
practical solution to Metro's Renton effluent problem. In reviewing the Draft
201 proposals—the choices seem to ba Alternative A-3 with an outfall at Point
HulloyCKouta C) or Seahurst Park(Houte A) due primarily to cost offectiveness.
Either of these are matched against an Alki Point outfall—Alternative A-5--
ad-nittedly a longer pipeline.
Going back to tha inception of the Renton disposal facility, was there no
concern by residents of South Park, Allentown, or others at that time about
potential contamination to tha Duwamish River? Was there merely no concern
about ecology or ware the parameters and data juggled to make it plausible?
Or was the political clout lacking to do otherwise? perhaps the same problems
' exist today with respect to the proposed new Renton sewage plant effluent out-
fall. I would guess that the effluent discharge into the Duwamish River was
utilized at that time based upon a least cost solution. It is now apparent
that least cost is «QT alwayaosst in making determinations. Yet the same logic
is baing applied currently in discussing A-3 Versus A-5. The sama rhetoric no
doubt existed over 20 years ago and in turn set us up for the current malaise—
contributing to the pollution of the Duwamish River.
To suggest that none of the solutions smack of political overtones would
be facetious if not dishonest. This was brought into the open by a King County
councilman who stated thit strictly between the A-3 and A-5 alternatives, regard-
less of any other considerations, a higher number of council votes froa tha A-5
affected area could eliminate that proposal in favor of A-3. Right or wrong
for any number of reasons, many small communities NOT oven in the Metro Sewer
Service Area(soma SOT iVEN AWARE of the plans)are being sat up to absorb the
impact of sewage discharge of a 650 square mile packago because it is politically
safe and economically justifiable to those within the Service Area? Costs can
ba juggled on paper and ecological parameters can be made to fit as necessary.
For instance, regarding ecological impact, in the entire EIS Draft only a
few para graphs (raf pg 123, EIS Draft)touch on the affects of the East passage's
SLOW and, in some areas, unpredictable flow. Not to mention tha impact of a
400;6(or mora)incraase to the 30 Million Gallons/Day discharge of the 7 existing
outfalls in tha East Passage exclusive of Tacoma/Commenseraant Bay. No impact
from an additional 144 MOD? Out of sight—out of mind???
Yet there was mention of some concern for another outfall at Alki Point be-
cause Sl-iGD of primary effluent is discharged there now. Only BMGD vs. gO I-CD
which is also only primary treated. Why so much concern about only 8 HGD uhon
Metro itself CONrlHnS throughout the 201 Draft numerous times(specifically, pg.
44 para3 & pg. 48 last para referencing Alternative A-5)that " Alki Pt. is a
preferable site over Pt. Pulley" and "Alki Pt. area is a mora suitable location
for effluent disposal than Pt. Pulley due I-1AINLY to the not northward currents
off Alki".
Paragraph 3, pg 39, 201 Draft—"A particle discharged in the araa(Pt. Pulley)
would probably flow south and around the west side of Vashon Island. Location
north of the pointplace the outfall away from the point and related tidal eddies".
Strange--! have a detailed currant study based upon U. of W. hydraulic model(you
are familiar with the Pugat Sound Hyraulic Model?)uhich indicated virtually con-
tinues eddies all around the Point Pulley area. PROBABLY—is that a"Kaybe"?
Maybe that particla would rather just circulate from eddy to eddy in the vicinity.
Seems that in dealing with a project of the magnitude, "MAYBE1s" shouldn't be
considered.
Assume a net southerly flow around Vashon Island. To date this portion of
Puget Sound has been able to assimilate the discharge of the existing outfalls
into the East Passage. However, neither the Craft EIS nob the 201 Draft deal
with the rapid growth of the East Passage adjacent areas. Will this blatant
omnission be corrected? Or again, since these areas are not in the Metro
Service Area, do we again have an "out of sight, out of mind " situation? And
although the Comroenoement Bay contamination appears to be localized, does that
" mean that Tacoma & Commenoement Bay will not continue to contribute to ecological
degradation? With or without an EPA? What about the combined effect in the
Tacona area with the introduction of a MAJOR new East Passage outfall into that
Slow Southerly Flow? No mention11111
I make the concession that there is a net southerly flow(although northerly
perhaps would have been better)however slow or variable, and that the waters of
the aast Passage have been able apparently to assimilate current discharges into
the ecosystem. But another point which seems to have been glossed over lightly
is that as much as 25'% or more of the northerly discharge of the flow around
Vashon Island through .Colvos Passage returns south into the East Passage I (per
Dr. Alyn Duxbury, Professor of Oceanography, U. Of W. 4 his findings with the
U. of W. Puget Sound Hydraulic Model)
Even without the mathematics of an empirical formula for a time/concentra-
tion study, this one aspect,alone specifies that at some point in the future the
East Passage must take on the characteristics of an enlarged Commencement Bay,
or closer to home, the lower Duwamish River. You are no longer diluting efflu-
ent—whatever the volume—into a totally uncontaminated water system, tha level
of contaminant concentration must continually increasel to what degree?—
Not mentioned! Not considered? For any other outfall south of Alki Pt.(aside
•from the suggested Pt. Pulley—and more specifically at Saehurst park or the
Lake Burien/152nd St. outfall) the problem would be exacerbated even further
due to reduction locally of ths net southerly flow, however slow or unpredict-
able, and to an increase of localized tidal action and current eddies.
(3)
f4)
-------
So—what are the reasons to not plan on the preferred Alki location?
Cost? There was the comparison at the public hearing of cost differential.
Tha figure promulgated was $100 million more to use the Alki location. But that
figure compares Alki to Seahurst Park which is less than desirable as would be
the Lake Burien/15?nd St. outfall. In comparing Pt. Pulley to Alki, I find the
differential per 201 Draft figures to be not $100 million but $?6 million
(Route C vs. Route D). However, other parameters have obviously been introduced
since the pipe to Alki is shown to be 144 inches vs. 120 inches for any of the
others. If those outside parameters are removed, »11 routes could be(and should
be for equal comparison purposes) 120 inch pipe. Then, even the 3 pump stations
of Route D(vs. tha 2 shown for Route C)might only cost $29.4 million vs $32 mil.
That is merely based on the per pump cost of Routes A, B, or C.
Also, a look at the associated easement acquisition costs indicate marked
disparity. Using the map on pg. ?Q, 201 Draft(admittedly a major simplification
of the subject), I find Route A with twice the easement segments of Route D,
Route B being 4.66 times Route D, and Route C to Pt. Pulley showing an easement
required for the full distance at 10.66 times that portion of Route D. Yet the
Pt. Pulley Route was allocated only 3 times the easement amount for Route D to
Alki. Cheaper land to cross? Maybe some back slapping between Metro and Port
of Seattle for the portion of the easement undar SEA-TAC Airport? If not,
explain the approximate $2.9 million differnetiall
Sunning up the cost comparisons now, I suggest the differential is not
$100 million(Route A vs. Route D), NOT $?6.9 million(Route C vs Route D with
. different diameter pipe), but probably less than $30 to $38 million—and you
still haven't dealt positively with the geology of the soil for that 27,000 ft.
tunnel to Seahurst Park or that of the 33,000 ft. tunnel to Pt. Pulley. You
can prove that it will all be(taaybe" 95jt anyway?)soft tunnelling so that the
costs don't increase substantially with more difficult soil—or become prohibitive???
Referring to any of the project costs: A-l, A-3, A-5, B-l, etc.—all have
the reference back to the underlying requirement. Clean up or reduce the pollution
level of the Duwamish River and thus help preserve the annual $5 million valu-
ation of the related salmon fishery. If COST is such a large factor—how are
ANY of the alternatives feasible when comparing an expenditure or $300 to $400
million to enhance or preserve $5 million in fish, ^fet there is quibbling over
whether to go from $279 to $310 million or as high as $357 million or more with
no downward adjustments. But it could all be in vain with future plans by the
Tacoma area to draw down additional water from the Green/Duwamish River system
for fresh water supplies. That would further the pollutant contribution levels
from surface drainage and any agricultural/industrial run-off to the river system.
As stated by an £PA representative at one .of the public meetings, "Unless
an overriding consideration, can be proven, federal grant assistance funds will
NOT be made available for other than the least costly proposal." Perhaps,
instead of'least costly", Better terminology should be—"most cost effective".
If the aforementioned does not establish sufficient logic or suggest
suspect planning,perhaps a detailed report of current conditions by HOAA
would aid in the prevention of an East Passage outfall. As I understand
it, data has been collected from current indioators in Puget Sound. The
project is part of an extensive long term study of the cross sections of
various strategic locations. This is not merely a duplication of surface
currents as such but a much more comprehensive undertaking with current
readings at varying intervals upwards from the bottom. The information
should be correlated and be available in approximately 9 months. The
compilation should definitely provide a more detailed comprehension than
that affoded by the Puget Sound Hydraulic Model a.s an aid in the decision
making process.
I suggest the NOAA Study information to be provided would then
establish that "overriding consideration" deemed necessary for federal
participation in other than the "least costly proposals" and that it
would greatly assist in confirming the fears of many people{ineluding
Metro & EPA representatives?)regarding negative impact on East Passage.
I have to assume at this point that Metro & EPA as "co-authors" of
the EIS are unaware of the NOAA project or else have chosen to ignore it
as a matter of expediency or otherwise.
Rather than seek a least costly solution to meet ndninum acceptable
and possibly questionable standards—why not approach the entire problem
• with a differnet viewpoint? Look for the most cost effective methods to
achieve the BEST solution possible. No question marks——to be dealt
with 20 years from now 111 //
Gloria L. J. Vermef
-------
Response to George C. and Gloria L. J. Vermef Letter of
February 17, 1981
1. Metro has indicated that an outfall to Puget Sound for
the discharge of Eastside wastes was first considered in
the original 1958 Metropolitan Seattle sewerage and drainage
study. At the time of the original Renton treatment plant
construction it was more cost-effective to provide a secondary
level of treatment with discharge to the Green/Duwamish River
than to divert the effluent to Puget Sound. The previous
decision is consistent with Metro's approach to focus on
the least expensive alternative that protects water quality
and public health. That decision did not foreclose the option
to construct a tunnel at some future date. When the Renton
treatment plant was constructed it was not known when or
whether a tunnel to Puget Sound might eventually be required.
At that time, the Metro Council committed the resources
necessary to monitor the river with the understanding that
the Renton effluent could be diverted if water quality prob-
lems developed.
2. See General Response Number 2.
3. Alki Point has stronger tidal currents than Three Tree
Point; however, there is no indication that currents at Three
Tree Point will not be able to adequately dispose Renton
effluent. Metro will perform additional studies at Seahurst
Park to ensure that a diffuser with adequate dilution (100:1)
can be designed.
4. Additional data on eddies at Three Tree Point were included
in the Final EIS (Chapter 6). Outfall design studies will
attempt to minimize effluent entrainment in shoreward eddies.
Experience with eddies around West Point indicates that eddies
may influence plume behavior. However, effluent does not
"build-up" in the eddies.
5. See General Response Numbers 1 and 2. The Final EIS
analyzed the combined discharges of Metro and other south
sound dischargers. It was not possible to project future
growth in all of the south sound areas, so present loadings
were used. Degradation of Commencement Bay and the Duwamish
River by toxic materials appears to be related to industrial
waste discharges, rather than treated municipal wastewater.
Recirculation of water around Vashon Island has been
accounted for in Metro's calculation of a final 1,500:1 dilution
ratio. This is approximately the equilibrium seawater .-effluent
ratio that would be reached in Colvos Passage.
6. See Response Number 21 to Puget Sound Water Quality
Committee letter.
7. See Response Number 22 to Puget Sound Water Quality
Committee letter.
8. See General Response Number 11.
9. The annual value of the Green/Duwamish fishery is nearer
to $10 million, as referenced in the Final EIS. See Response
Number 15 to Puget Sound Water Quality Committee letter.
10. Regarding future influences on Green/Duwamish River
water quality, the Final EIS considered the effects of in-
creased Tacoma diversions on the water quality of the Duwamish
estuary (Chapter 6), and also the general effects of non-
point source pollution from population growth (Chapter 7).
11. Current velocity measurements in the vicinity of the
proposed discharge location would be valuable in evaluating
discharge conditions. Metro may obtain such data in its
outfall design studies.
-------
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,
haufi (Jb~~-
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20 0
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ESN 31-11 (1980)
und to exist (i.e. similar E and H plane
tterns) with low cross-^polarlzatlon
Three papers from the Technical High /
hool (Poly technique) of Lausanne. In /
Itzerland, were delivered by J.C.E. /
soon. The first paper, "TOxi Reflection
Open-Ended Circular Waveguides. * which
coauthored by S. Mamane and K.E. Sar-
1, discussed the use of a flanged^
egulde mouth for the nondestructive
ermlnatlon oY the dielectric proper—
a of tissue Iti blomedlcal applications.
. waveguide Is
. tissue which
ly the field lr
the Interface
jdy, which was
ilnst considera
julred numerica
atantlally frequency Independent b&
pointing system waa obtained by thyls method.
In this writer's, opinion there arii simpler
methods of obtaining beans from Jrlne sources
iplexity. (Bes
jllshed almlla
.ch an open-end
laced righ^ against
la very lossy so* that
the Immediate /vicinity
Is of relevance. The
theoretical, tame up
ble difficulties and
l calculations of high
jon had previously
Investigations in
d coaxial' transmission
that dp-TTO-t--^can with freqi
have less comply hardware
this compensatlorKmethod, i
ingenious as It
a cost-effective praVtl
The conference cty
and achieved broad pa
over Europe. Regre
presentations had vl
so cramped with
equations and info-fmatloJ
digestible. The^
to become an eo/Satio
universally difficult to
present Idea/ In their
equations to the written t
dlx. If ifnat can ever be
.
ie had been used\as a prj»be, and in
.ch the first measurements had shown
•d agreement wltA numerical results.)
aecond paper, "Boll Moisture Determina-
»n: Experiments with passive Radio-
-ers," was authored by1 P. Neylan, C.
•rler, and R. Calol Drom Lausanne and
Schanda and Ch. Nat/ler from the Uni-
•slty of Berne. They found an experl-
.tal relationship between emlsslvity
soil moisture coiiQent, particularly
middle-heavy and lUght soil; however,
y also found a strong dependence
surface roughness and Interfering ef-
ts of vegetation cover. The third
•er concerned cprrenu distributions
micrpstrlp rao"lators\
A very cleve^r and iripenlous antenna
described by workers from Thompson
1 In France, In a paper, titled "The
smatlc Array Antenna, fe Nondisburslve
.vellng Wave/Array Antehna," written
S. Drabowitch and M. Dudome and pres-
.ed by the Aatter. The Antenna uses
end-fed waveguide feed-Array (e.g.
-h slots o/r dlpolea) which gives a beam
.t oquintst at some angle off broadside.
squint Angle Is a function of the
•ment spacing In terms of Vavelength
la therefore frequency dependent.
radlaylon from the waveguide Is con-
ned between parallel plates and Is
ercepyed at some angle by what amounts
a lend formed by an array of a comblna-
>n of /receiving horns, phase-shifters
! transmitting horns. The phkse-shif ters
•e substantially frequency independent
ise-ahlft and are arranged in !tuch a way
t a /beam cornea off at broadsldV to the
.t aerture. The frequency Independent
causes the radiated beum to
as a function of frequency.
: various constants were chosen sVich
it this scan cancels that scannink which
due to the end-fed feed-array. A; sub-
rand that
rementa;
sting and
ely to find
ppllcatlon.
many subjects
ipatlon from all
many of the
phs that were
handwritten
as to become In-
ed the speaker
r. It seems
t speakers to
relegating
or Its appen-
.leved, perhaps
mpte
It alsoy*lll eliminate some of the papers
that aWow admirable skill In solving very
dlfftfcult but regrettably unimportant
problems. (T.C. Cheston)
ENVIRONMENT
ENVIRONMENTAL PROTECTION STUDIES IN SOUTHERN
FRANCE
Le Centre d'Etudes Techniques de
1'Equlpraent d'Alx-en-Provlnce Is one
of six regional centers In France which
combine some of the activities that in
the US are performed by the Array Corps
of Engineers, the Environmental Protection
Agency, and the Department of Transport.
The center in Alx-en-Provence is the
largest, with 650 employees. These centers
are Jointly administered by the Ministry
of Environment and Quality of Life and
the Ministry of Transport. They were
originally set up to handle engineering
and other problems associated with the
postwar explosion In highway construction
and this is still their primary occupation.
However, they have branched out into
many other fields Including land management
and urban planning, urban and interurban
traffic control, highway safety, public
hygiene, harbors and waterways, information
and management systems, management of
economics and finance, architecture,
and all types of civil engineering, and
protection of the environment. Research,
design, and management studies are made
for governmental bodies at all levels
as well as for private companies and
individuals.
This article Is concerned with en-
vironmental studies. One subject of
Interest to me after 22 months in noisy
London Is traffic acoustics. Noise levels
associated with traffic come under serious
515
&y^^iff^vw^
li. i p ntfrtftrr**i "i Viiir'Ail'uj^rTr'ir'ir r't-.-irpi"."n-|'T[i i \UiinrWii i •••vT.'j ''riijji'ir « iTinnfcX'U &•*****£•£ ^i
ESN 31-11 (1980)
consideration at the center. Acoustics
are taken into account In the dealgn and
placement of highways and In the materials
used In them. Architects of proposed
apartment houses and office buildings
thut are to be built close to busy highways
S- may come to the centers to receive concrete
*• advice on how to sound-Insulate to keep
traffic noise at an acceptable level within
the structures. Center employees monitor
' noise levels within the buildings after
they have been constructed to determine
the effectiveness of their advice.
The synoptic contoured picture of §tudy on th
the dye distribution resulting from aerial .oncentratl
photographs which cannot be obtained In
'•tudy of th
The first major study was off Pro- 'lions of sa
prlano, a resort city on the west coast *ter at va
of Corsica. During summer the population -eles of i
there Increases by a factor of 10. Local -p It wao
authorities wanted to know if any effluent . ^ or the '
There are several individuals working f from the present sewer outfall approached ^ earch on
'-'— " ~ "" -- tj)e iocai swimming beaches. Local currentiff,. wr*inn
j on various aspects of marine pollution.
\ Dr. Claudine Valerlo and her collaborator,
'Engineer M. Llebarla (Laboratolre d'Astron-
; orole Spatiale, Marseille) have developed
"i-^iV, a quantitative multispectral remote-sensing
y^SJi system employing aircraft and cameras
to measure ratea of mixing and diffusion_
"and "movement, of pollutant a ne"ar_.ah"ore_._'_ ~
SS?IS£ 'lt la uaed Prircari-ly in the planning fo?
ifc5j&w improving aewer outraii systems.
Rhodamlne dye Is introduced into
jlf, coastal waters through an existing sewer
[£ outfall or at the location where one is
proposed. An airplane files over the
area for about 6 hours taking frequent
^ photographs of the dye plume at various
stages of the tide. Two cameras are
used. Filters are employed so that one
camera photographs light at the wavelength
of the peak of fluorescence and the other
photographs the blue part of the spectrum
outside the spectra of the rhodamlne.
_ The negatives are digitized on a PDS
il. 1010A mlcrodensltometer of very high
e£ accuracy. A computer is then used to
j5: calculate the amount of dye In a vertical
[g_ column extending from the surface down
£? to the bottom of the plume (depth • z)
\:, at grid points (lOOu x IQOu) on the
j; negatives. The quantity of dye, q(z),
£?• Is then contoured In g/cmz . Corrections
^iare made for experimental conditions:
$. the angle from which the light is coming,
r)" sea and swell, and turbidity.
•£ Density on negatives Is calibrated
^' in terms of illumination and then q(z)
* in several ways. First the water is sampled
,v. at several depths and at several locations
&. In the plume and the dye concentrations
jT are determined in the laboratory with
•„** a fluorescence detector. After Integrating
?*J.q(z) with depth the results give the amount
£-.'of dye where each set of vertical samples
f. was taken. The relative value of llluralna-
*~ tlon is then plotted against this amount.
$$. Valerlo has developed a theory of fluores-
'•"' cence that links the known total quantity
of rhodamJne dye In the plume directly
were measured by following the paths of
floats with sequential air photography,
while rhodamin was continuously released
through the outfall and photographed
from the air.
The study showed that sewage would
come into beaches during some phases of t
the tide and under certain wind conditions
In order to continue to use the present to
wrltlnt
bad slowed i
oonstructloi
to divert fi
pollution.
will go intc
nuclear
After \
.ait Lat
outfall and not pollute the beaches, the ^"tionfll d't
sewage would have to be thoroughly treated . onstra*
before discharge. • nuter svt
Another study is underway off Atlbes *?? J-orms o
near Nice to locate the distance from ml _._ w_ i
shore that would be optimal for a new
sewer outfall. First discrete amounts
of dye (600 g) were placed In three
locations, three times a day and were
followed by alrcraft photography. A
"guessed" best location was selected from '
as Vale
noalcal phot
flonversfttlor
used that gt
presenting t
~ ' tlvely u
these observations, and a continuous
source of dye plus floats will be used
In a study similar to the Propriano study,I"
The method Is now fully operational. 1 I
Valerlo has studies In progress at I !
several locations on the south coast of -^
•yateffi.
MATERI
SCIEIMC
i to density distribution of the negatives,
''and contours can be accurately drawn without]
actual samples. The system Is accurate
to within 5 percent.
516
Prance where she Is observing the movement?0 '—
of visible effluent from outfalls near rln*
high cliffs. She mounts a spectrophotonet A \
on the top of each cliff. The areas eoncernea HA
around the outfalls are very slowly 3canr,ie'rilj:0 Jh
by optics focused on the npectrophotomete-&'l" •*, *
and over the visible and near-infrared Research anci
part of the spectrum. The color of the gorth Atianc
\ waste water Is clearly seen through the B>e rlr" ,
use of four narrow-band filters. The Surface Envi
results of the spectrophotometer studies ri»ls» i"aST
are used to determine the most useful 17 April. 1.
spectral channels for more detailed alrcr^^ectfl
data acquisition In order to obtain JP°n Avlonlc
photographs with the highest contrast. from 10 to I1
The aim of these studies is to develop X>1? ttle L-
an efficient methodology for Inventorying <""• "• Ju!?e'
coastal pollution. The spectrophotometer>' the At"*n
Is calibrated with clean water and has >Tervle>c of
a reference beam focused on a white cloth in ^)'Btloniw. "
to take Into account variations in sunllg-lubc's talk t
I also talked with Mme. G. Blcheron,V>lch had to
head of the chemistry group at the center.t«P°olte ma
This group Is also working on marine 'l/.tecs from
pollution research. It is doing a pilot r»*en togetb.
I f«lrly era;
to which coral
(»rbon-flber
-------
ESN 31-H (1980)
are replacing aluminum and titanium alloys
In aircraft construction, aa well aa
problems associated with this replacement.
Proceedings of these meetings will
publlshedvby NATO (obtainable from
Report Dlkt-rlbutlon and Storage Uni/
NASA Langlby Research Center, Hampton,
Va. 23661)}
It la Useful to realize the i
a
3
i
I
i
fc
1. See Response Number 18 to Puget Sound Water Quality
Committee letter.
2. See General Response Numbers 1 and 15.
3. Oceanographic studies will be designed to ensure that
an outfall diffuser can achieve 100:1 initial dilution. A
see General Response Number 15.
4. See Response Number 4 to Jeanne L. Snell letter.
Also,
5. The final plan recommended program leaves open the option
of effluent from the north part of the study area being dis-
charged via an ocean outfall from a Kenmore treatment plant.
6. Sufficient capacity is currently provided in the proposed
outfall to accommodate flows from the north part of the study
area, and if these flows are not diverted to the Renton plant,
capacity considerably in excess of 50-year needs would be
present. EPA, by its regulations, is not allowed to fund
outfall capacity above 20-year needs, or if certain findings
are made, 40-year needs. EPA as a general rule may not res-
trict the size of the outfall to 20-year or 40-year needs,
but rather requires capacity in excess of these needs to
be paid for entirely from local funds.
-.^--v''^
-------
„ THOMAS J. TAAFFB
~lJTvf•"?T"""n "; ".'"•; DOUGLAS H. MORKLAND
» ^ :-'-'••• — , '. ATTORNEYS AT LAW
•jjj «i7 SQUTHWtaT .»a~o
'' " fEB 231981 BCATTUt.WAaHINaTQN»BI»6
February 18, 1981
U6N. sumjiii
BUNCH
U. S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, WA 98101
Attention: Roger K. Mochnjlck M/S 433
Re: Metro Tunnel Renton-Pug«£_Sour.
Dear Mr. Mochnick:
I am a resident of the Gregory Heights area which overlooks
Puget Sound near Three Tree Point - Seahurst.
I have reviewed a ream of material mostly objecting to the
proposed effluent tunnel. It is obvious that many intelligent and
motivated people have presented cogent arguments against the
proposal and have taken a great deal of time to support their
arguments with scientific and statistical evidence.
It seems to be, that argument after argument omits what I
consider to be the long-range disaster ticking away behind the
proposal.
It is true that there are serious immediate problems resulting
from the discharge effluent - even secondarily effluent - into
Puget Sound this far south. The problem will be doubly compounded
if Metro ever obtains a. waiver to allow only primarily treated
sewage to be dumped into the Sound. But the real problem lies
with the fact that this tunnel will make it easy in the future to
justify increasing urban sprawl. I refer specifically to
continuing development through the farm lands to the east. This
is the real pea under the shell of this proposal. The advocates
of what is mistakenly considered to be progress have every intention
of expanding development in King County and the surrounding area
eastward from Puget Sound to the Cascade Mountains. This is not
an idle statement. Talk to the real estate brokers and the land
speculators. They will tell you where the "action" is.
The problem is that development to the east will be doubly
disasterous for the ecology of this area. The damage to the physical
environment by increased sprawl and development is obvious. The
damage to the environment by an increased drain on natural resources
U.S. Environmental Protection Agency
Page 2
February 18, 1981
and drain into natural resources which is the subject of this
letter is equally obvious. The increased demands on our transporta-
tion system and our very limited energy resources as a result of
expended development is less obvious. But the fact is, the more
sprawl the more transportaion required. It is axiomatic.
Obviously, the proposed sewage tunnel is not going to be the
cause of urban sprawl. But it will make urban sprawl so much
easier. How easy it will be for future developers to explain to
the environmental protectors of the future, how neat and clean our
developments will be because of the sewage system. How much more
difficult it will be for them to complete their plans if it is not
so easy for them to dump their mess in Puget Sound many miles to
the west.
Very truly yours,
Thomas J. Taaffe
-------
Response to Thomas J. Taafe Letter of February 18, 1981
1. EPA recognizes the role of the Wastewater Management
Plan in ac'commodating urban growth, and has devoted an entire
chapter of the EIS (Chapter 7) to considering the adverse
environmental impacts of growth accommodated by the plan.
EPA has also listed mitigation measures to avoid or reduce
these adverse environmental impacts. The Metro plan is con-
sistent with approved EPA population projections and with
local land use plans, and EPA may not refuse to fund the
Wastewater Management Plan merely because it provides capa-
city to accommodate planned-for urban growth.
-------
•ii^^f^-^g^jfe^^s^^sK^^isT^^M^^s-'S^is
^/""••t-^NV^v.i.Vi-'^^^-vJ^^^
^:^^&^^^f^S^£^^i^^&^^^^£2£S^&S^i
1200 -
a-^-?/
Response to Karen and Mel Barbian Letter of February 24, 1981
1. No response required.
/?- 3 , &>^ ^ -TZ^fr ^^^^,
^^^A^^^^^ ^^^ -X^^-
tD
FEB 25 1931
ENVIRONMtNTM. EVALUATION
BflANCH
-------
-.
Barry C Maulding
General Counsel & Assislani Secretary
February 23, 1981
Neil Peterson
Executive Director, Metro
Exchange Building
821 - 2nd Avenue
Seattle, WA 98104
Re: Renton 201 Study
Gentlemen:
I am very upset with Metro's apparent approval and recom-
mendation to adopt the Metro preferred plan for dumping
sewer effluent from the East side of Lake Washington into
Puget Sound in the Seahurst/Pt. Pulley area.
Complete studies need to be conducted to indicate the bio-
logical damage to marine and shore life with e 100 million
gallon, per day dump into one low current Puget Sound loca-
tion.
Our intuition tells us that pumping this volume of effluent
per day into an area of relatively low current, tide and
eddy activity significantly increases the probability of
eventual fouled beach water and contaminated shellfish.
Metro officials admit to a possible 250:1 dilution at the
shore line is probable. At best, this option is a calcu-
lated risk where the stakes are very high.
There are alternatives other than Seahurst that make a. lot
more sense from an environmental and economic perspective.
Adopt one of your own, but slightly more costly alternates
(Bl), to treat the effluent to a higher degree discharging
as presently is done, with the additional load routed
through Kenmore to the North Sound for a two location efflu-
ent dump into a high current area. The additional cost of
$.50 per month, per household, appears the most-palatable
solution to reduce the ever increasing total Pi'_
pollution problem. If")]
i
FEB 25 1981
ENVIRONMENTAL EVALUATION
BRANCH
Alaska Airlines. PO Box 68900. Seatlle. Washington 98188. (206) 433-3139
Alaska Airlines
Neil Peterson
Febraury 23, 1981
Page Two
I resent your encroachment on our community with this ex-
pedient approach. Long after the planners and researchers
have moved on, we will have to live with the beaches and
water in our community. Please give us the same considera-
tion that you would if you lived here yourself.
Collectively, we as citizens of Seahurst, are firmly united
and organized against this proposal. We are prepared to
exhaust every available political and legal avenue to halt
this development.
Sincerely,
BCM/mm
cc: .Roger Mochnick M/S 443^
Ron Dunlap, County Executive
Paul Barden, Councilman
Editor, Seattle Times
3JSJj^^^'^^^~?'; ;vV:".',: ^??¥Z^^ £t|p|^£Ji^3j^
-------
Response to Barry C. Maulding Letter of February 23, 1981
1. See General Response Number 1.
2. Alternative B-l would not completely protect water quality
and fisheries in the Duwamish River. This consideration,
in addition to its higher cost, was the reason it was
not selected.
-------
FEB 26 Iflffl
' • -VALUATION
12009 30th Ave. S. VI.
Seattle, Wa. 98146
25 Feb.
Snviornraental Evaluation Group
H. P. A.
1200 6th Ave.
Seattle, Wa. 93101
Attn: Craig Partridge
Gentlemen: I
The following summarizes my telephone conversation of this
morning with Mr. Partridge.
The discharge prooosed by Metro from their Renton Secondary
treatment plant is not going to be well received by the local
beach property owners and dwellers in the proposed outfall
are-ts near Seahurst Park and Three Tree Point (Point Pully) •
I have talked with my neighbors and without exception they were
willing to sign a protest petition.
This proposal has raised questions about giving the discharge
additional treatment at the plant to then enable continued
discharge into the Duwamish River. Other cities as Qenver,
Fort \Vorth and lallas have so me way to dispose of their sewage
without pining it to saltwater.
If Hellevue is a "Duality Town" why c-m't they treat their sewage
in a better -lanr.er than to dunra it into the Sound to let the
Salt 'Vater "take care of the problem" in the heach dwellers front
yard?
The -lischarae in the Seahurst/Three Tree Point area will flow
southward to Tacoma and thence northward through Colvos Passage
whereas the discharge from "Jest Point, and oartially from Alki
Point, is carried more directly northward to go out the Straits.
A mmber of boat owners have questioned the °quitability of
reiuirinf, pleasure boats to have holding tanks and treatment
equloaent when the quantity of discharged matter every day from
ttia Renton olant will far exceed, even after secondary treatment
the total from all the boats in the area.
Information re-arding the coast 3-uard enforcement of EPA regula-
tions on snail boat sewage discharge was obtained by calling
442-535") • The Coastguard' was required by "33US3 1322" of 13
Oct. 1972 to »i,force'SPA standards Partl40, Title 40 GFH and
33 0VH Part 15O for enforeenent. Further information may be
obtained at th~ a^ove ohonn number. I hooe this can b
-------
JAN 27 1981
January 22, J9F1
211 S'.J 196th Plaon
'-Ja. 9P1S6
Municipality of Metropolitan Seattle
Exchange Building
821 Second Avenue
Seattle, Wa 981CA-
Attni Ms. Gerry Larrance, KS 73
Rei Comments, Renton 201 Study
Dear Ks. Larrance, unmiwi
I was pleased to SOP the large turnout at tho January 13th
meeting at the Burien Library. Although I was able to make one point at
the rceetlng, I would like to add several more comments for the record, even
though they probably have already boen submitted by others who live closer
to the proposed outfall.
KIS Concerns
Ky experience with EIS documents has been that the projncted Impact
does not appear to be a problem as documented, but then a year or so later,
after the development has been made, no-one is responsible to follow-up
and ensure that the design functioned as planned and to force corrective
action In the event the design does not work as promised. This leaves the
burden on some Impacted property owner to sue a government) which Is a very
expensive recourse. Another experience has been that agencies have these
public hearings, record the publics' comments and concerns) and then go ahead
and do what they wanted to do in the first place.
The biggest problem I see with this EIS, howovnr, Is that It is
being prepared by EPA. Who, then, is representing the people In an impartial
manner? It is not right for the agency that Is chartered to review and approve
the EIS to be the one working with KETRO In the preparation of the document,
especially when the inpact is broader that the area covered by the EIS such
as outside the KETRO service area. EPA should Immediately disassociate them-
selves from the Renton 201 Study EIS preparation so that they may Impartially
review the future proposal.
Inadequate faster Plan
The Renton 201 Study appears to have been developed without duo
consideration of tho requirements/plans of adjacent areas. In my opinion,
the plan to divert (I question the legality) large quantities of sowage from
other drainage basins, as far north as Bothell, to an allroady overloaded
plant at Ronton while a large amount of land south of the Rnnton .plant and In
the same drainage basin Is yet to be developed. This is not fair to thn south
end of the county. I recognize that a. largo part of tho problem is tho lack of
a King County Planning Commission properly constituted per ROW 36.70, that will
ensure equitable development and controls over tho entire county. KETRO,
however, has to recognize that its planning has a tremendous impact upon land
use and that it is very Inportant to put this Renton 201 Study Into perspective.
That was net done. Most casual observers of the planning process do not consider
Botholl to be a part of Renton. For example, I understand that aftnr the rnpalr
of the '/tast Seattle bridge, the Port of Seattle hopes to widen tho Duwamlsh
River to' 300 font are) deepen it enough to allow largo ocean golns; shins to como
up as far as Ox-Bow (near thn Boeing Development Center). This could hav*
a larpio Impact on the capability of the river to handle the Renton plant's
wastn dun to the salt water Inflow. Is that a hidden reason for this diversion
tunnnl proposal? I did not son any statement of tho Port's plans In tho
summary EIS statement.
Thoro was no discussion In the meeting on why the waste from thn
west side of Lalco Sammamlsh, that currently Is eolrvr to Most Point, shoulrt be
dlvortod to Kcnton. Is that so the Richmond Beach plant can be closed? There ,_.
was no Indication of the expected growth of the North Seattle area as a just- i.6)
IfIcatlon for the off-load of the majority of the north county waste to the
Renton plant. Alternative B-l Included a 75& expansion of thn Renton plant
so that was not really an alternative that would help the south end.
From my experience as an engineer, I seriously question all of your
dollar comparisons. For example, a better understanding of the soll/roel:
characteristics for the tunnel routes can easily double the cost of the tunnel
making that plan the most expensive. In addition, the total cost of the future
trunlcs and pumping stations required to divert waste from Bothell to Rer.ton
must be added to tho development costs. You should aslc your consultants to
provide a band of costs for each estimate so that you have a best/worst cost
range upon which to base your decisions. This is because various types of
construction have quite large deviations in the accuracy of a cost pstlnatc.
I doubt if KETRO Is much better than ViPPSS in controlling thn costs to incorn-
orsto mandatory or "make work" design changes in a construction contract. In
other words, I believe that the relative cost data should take a back seat In
all areas except whom you can clearly show a large difference In operating
costs after construction is completed.
As I proposed in the meeting, I believe that waste raters should not
be diverted to the overloaded Renton plant but diverted north to a new facility
In fact, the proposed plan appears to be an illegal diversion of wastes into
another drainage basin. With careful planning, you could also bias the nnw
developments of industrial facilities so that a better centralization of
industrial toxicants can be maintained to reduce operating costs. I bellnvp
you still have the ability to bill a customer for the extra costs of handling
his toxic wastes. A plan should search for a method that would divert the
toxicants from many small industrial plants to a custoelzrd treatment facility I _^^
that can handle the waste in a most cost efficient Banner. Kot all companies |(lO)
can afford to spend as much as we do at Boeing to treat wastes. All these Id pad ~i
should be Incorporated into a new 201 plan for tho north end of the county. j
Local Impact
Tho Ronton 201 Study proposes to load the "drainage capacity" of
the Hlflhllne area with 99,000,000 gallons cor day of grey water. We are not
In KETRO. Within Hlehllno, we have a relatively large number of areas that are
currently not on sowors and need to be annexed. If wo continue with current
"residential" developments for the Hlphllne area, there will br llttlp pnnrratlon
of toxicants and hence no need to expand our plants to secondary treatrent.
Tho only doubt I havo in that area Is the lart-e growth of industrial par): type
plants in the area batwenn the SoaTae airport and Des Koines planned by the
Port of Seattle. That may result In a large amount of toxicants beIn? diroctrd
to tho DPS Kolnos Spwnr District and hnnco require secondary or bettor treatr.ont.
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Probably some control on the type of industry should be imposed; however,
I do not Icnow who would faco up to that a political hot potatoo. There
are, therefore, many factors that must be studied in a "Hig'.illne Area 201 Study"
before wo will Unow t/.o ability of the area to accept any of the Renton output
after meeting the needs of our local Sewer Districts.
I bollnve that you now recognize that the Ronton201 Study recommendation
is not acceptlble to the Hlehllno and '.-test Seattle areas. I strongly recommend
you table the study pending completion of similar 201 studies for the rest of
King County, You need a much more complete story to achieve credibility and
endorsement of your proposal, When the people of Hlphline recognize that you
plan to shut down the Alltl plant and divert that waste water to Renton and
thence to Hlehline, they will be very unhappy. It does not appoar that your
proposal will ever be acceptable.
CCi Environmental Protection Agency
Southwest Suburban Sewer District
Des Koines Sewer District
Lake Haven Sewer District
Highllne Community Council
Response to Ray Pederson Letter of January 22, 1981
1. Although in general monitoring of environmental impacts
following completion of an environmental assessment is often
lacking, in the case of the Metro Wastewater Management Plan,
detailed oceanographic and biological studies will be con-
ducted during the design of the project, and Metro is com-
mitted to a long-term monitoring program for water quality
and biological impacts of the Renton discharge to Puget Sound.
Also, the Washington Department of Ecology issues and enforces
effluent discharge permits for treatment plant outfalls,
which contain requirements for effluent characteristics.
2. See General Response Number 13.
3. See General Response Number 13.
4. The final plan recommended program defers the decision
on where to treat wastewater from the north part of the study
area to the Renton plant, thus reducing interbasin transfers
of wastewater.
5. See General Response Number 3.
6. See Response Number 4 above.
7. See General Response Number 11.
8. See Response to comment Number 4 above.
9. See Response Number 9 to City of Normandy Park letter.
10. Regarding cost allocation to industrial uses, see General
Response Number 12. Decisions on zoning for industrial develop-
ment are the responsibility of local general purpose govern-
ments, not Metro or EPA.
11. There is no obvious relationship between selection of
a wastewater management plan for the Renton study area and
meeting the long-term sewerage needs of the East Passage
area. If the commentor assumes that Puget Sound has a highly
limited assimilative capacity for wastewater that future
discharges from East Passage communities would completely
utilize, there is no evidence to support this idea.
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February 1, 1981
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3 1S31
Ms. Gerry Larrange
METRO
821 Second Avenue
Seattle, Washington 98104
RE: RENTON 201 STUDY
Dear Ms. Larrange:
Your proposal to dump sewage outfall from Metro's Renton treatment.. •
plant to Three Tree Point is totally unacceptable for the following
reasons:
1.
2.
3.
4.
5.
Currents would send the effluent south instead of flushing
it directly north out of the sound
Protection of valuable salmon and sea life in Puget Sound would
be threatened from lingering sewage that would lie in South Sounc
Response to Carolyn Bolstad Letter of February 1, 1981
1. See General Response Number 1.
2. See Response Number I to City of Normandy Park letter.
3. See General Response Number 2.
4. See Response Number 2 above.
5. See Response Number 9 to Beth Savage letter.
This outfall is not "our" sewage as it originates from Kent,
Bellevue and Mercer Island. Furthermore, Metro doesn't even
serve us at Three Tree Point.
S.W. Surburban Sewer District already operates two outfalls to
serve our local needs and unlike Metro, they don't include any
wastes from heavy metal industries.
There is also a matter of principle. Should Metro which does
have legal authority be able to jam down the throats of people
it doesn't serve a project they don't want??
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There are alternatives that would both save the Duwamish and keep
Metro off our Beaches. One option that looks very good, but was left
out of Metro's draft plan would be to pipe the effluent from Renton
down the Duwamish, out of the mouth of Elliott Bay and discharge it
deep into the northerly currents of Puget Sound. This idea was too
hastily dismissed and deserves at least as much consideration as any
other. It appears to be environmentally sound and has little or no
impact on residential areas. It was pointed out however, that the
costs of piping down the Duwamish was very little more than piping
to Three Tree Point. After the small difference is prorated among
all those being service, it would amount to nothing compared to the
problems and costs you would incur in cleaning up the sound at a
later date.
Your reply to this alternative would be appreciated.
Attn
EPA Region X
1200 Sixth -Avenue
Seattle, Wa 98101
; Roger Mochnick
M/S 443
Sincerely,
A very concerned citizen of
South Sound Three Tree Point.
Carolyn Boystad
16047 Maplewild S.W.
Seattle, Washington 98166
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February 9, 1981
To: Neil Peterson
Executive Director, Metro
Exchange Building
821-2nd Avenue
Seattle, Washington 98104
Re: Renton 201 Study
ENVIRONMENT*. ElOLUATt6«
HUNCH
Response to V. Selivanoff Letter of February 9, 1981
1. See Response to Barry C. Maulding letter.
I am extremely angered at your agencys1 apparent approval and recommendation
to adopt the Metro preferred plan for dumping sewer effluent from the East
side of Lake Washington into Puget Sound in the Seahurst/Pt. Pulley area.
No complete studies have been conducted to indicate the biological damage to
marine and shore life with a 100 million gallon per day dump into one low
current Puget Sound location.
Our intuition tells us that pumping this volume of effluent per day into an
area of relatively low current, tide and eddy activity significantly increases
the probability of eventual fouled beach water and contaminated shellfish.
Metro officials admit to a possible 250:1 dilution at the shore line is probable
At best, this option is a calculated risk where the stakes are very high.
There are alternatives other than Seahurst that make a lot more sense from an
environmental and economic perspective. Adopt one of your own, but slightly
more costly alternates (Bl), to treat the effluent to a higher degree dis-
charging as presently is done, with the additional load routed through Kenmore
to the North Sound for a two location effluent dump into a high current area.
This additional cost of 50<£ per month, per household, appears the most palatable
solution to reduce the ever increasing total Puget Sound polution problem.
We resent your encroachment on our community with your quick fix approach.
Long after the planners and researchers have moved on, we will have to live
with the beaches and water in our community. Please give us the same considera-
tion that you would if you lived here yourself.
Collectively, we as citizens of Seahurst, are firmly united and organized
against this proposal. We are prepared to exhaust every available political
and legal avenue to halt this development.
Thank you,
cc: Roger Mochnick M/S 443
1200-6th Avenue
Seattle, Wash. 98101
Paul Barden
Seattle Times & Seattle P.I. '
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Seattle, WA
February 18, 1981
Mr. Nell Peterson
Executive Director, METRO
Exchange Building
821 - 2nd Avenue
Seattle, HA 98104
Response to Lars Holmberq Letter of February 18, 1981
1. The Renton discharge would be designed to be far enough
offshore and of sufficient depth to maximize dilution and
minimize shoreward contact. Field studies would be under-
taken to conform to the suitability of the location. No
major water quality impacts are predicted with a Seahurst
Park discharge. (See General Response Number 1.)
Reference:
Dear Mr. Peterson:
Renton 201 Study
I am hereby registering my strong protest against your plans A3 and A5 for
discharging sewer into the Puget Sound waters along the shores of West Seattle
and points south.
It seems to me that A-l is the most sensible approach even though the cost may
be greater. I suggest that you personally take a good look at the water near
the shore on incoming tide - a nice warm summer day along Seola Beach, and see
1f you would like to swim in the cesspool that already exists by the discharge
from the existing sewer treatment plant in Shorewood.
It 1s hard for me to believe that any expert In the sewage disposal field could
conceive and propose plans which will add to already existing problems, c
Should you. against better judgment, select either the A3 and AS plan for Imple-
mentation, rest assured that I myself and many of my fellow community meraLers
will initiate whatever legal steps are necessary and appropriate to stop such an
unreasonable, expensive and ill-conceived plan.
Lars'Kolmberg
12515 Shorewood In.
Seattle, WA' 98146
S.H.
Ron Dunlap
Paul Barden
vRoger Hochnick
Hamilton Underwood
Betty Lunz
Cheri Zehner
Charles Henry
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February 24, 1981
Mr. Neil Peterson
Executive Director
Metro
Exchange Building
821 Second Avenue
Seattle, Washington 98104
Dear Mr. Peterson:
RE: Renton 201 Study
Response to Nancy Hahn Letter of February 24, 1981
1. See General Response Number 1.
2. The final plan recommended program defers the decision
on where to treat flows from the north part of the study
area.
I am writing to express my strong opposition to Metro's preferred plan to dump sewer
effluent from the east side of Lake Washington into Puget Sound in the Seahurst/Pulley
Point area.
It seems incredible to me that this low current, low tidal activity area would even be
under consideration. As I understand your plan it will involve the dumping of 100 mil-
lion gallons of effluent per day and that will certainly increase with the passage of
time. I do not believe that the Seahurst/Pulley Point area can handle that huge amount
of sewage.
It may be more costly but I would favor the route through Kenmore to the North Sound
area. As a resident, of Ssahurst I would like to see consideration given to the protection
and preservation of the delicate balance of sea life in Puget Sound.
I believe this plan would seriously increase the already present pollution level of
the Sound. I think that now is the time to give more thought and perhaps spend more
money to go with the safest alternative we can find for Puget Sound, not the most con-
venient plan. Seattle's environmental quality lias been decreasing at an alarming
rate and I think ycu owe il to the people of the Puget Sound area to give a more
thoughtful appraisal to a plan th.it will benefit and insure that tho quality of Puget
SounJ remains for everyone to enjoy now and in the future.
Sincerely,
Nancy llahn
12221 Sliorewood Drive Southi;est
Seattle, Washington 9S146
Charles Henry
Director of Water Pollution Control
Roger Mochr.ick
EPA, Region X
Ron Hun )r<]<
County Executive
Pntil Itordrn
County Councilman
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Response to K. Selivanoff Parker Letter of February 25, 1981
1. See General Response Number 1.
2. The cited letter from Roy Ellerman, addressed to Bruce
McKnight of Southwest Suburban Sewer District, was referring
to the question of whether the East Passage area could be
considered "open ocean". If it could, federal requirements
for secondary treatment that existed at that time might have
been waived. The letter's conclusion was that, since water
circulation characteristics of the area prevented its classifi-
cation as "open ocean", secondary treatment was necessary
for any sewage treatment plant receiving federal funding.
Effluent from the Renton treatment plant will receive secon-
dary treatment.
3. See Response Number 1 to City of Normandy Park letter.
4. See General Response Number 8.
5. See General Response Number 1.
6. See Response Number 12 to Puget Sound Water Quality
Committee letter.
7. See General Response Number 2.
8. Alternatives which continue discharge to the Duwamish
River are not considered to fully protect water quality and
fisheries.
8. See Response Number 11 to Mary Ellen Hamblin letter.
h 11 tze.
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