n -^ 83 001
EPA-910/9-82-091
United States
Environmental Protection
Agency
Region 10   .
1200 Sixth Avenue
Seattle WA 98101
                            EPA/10 Anchorage AK WWTW-82
              Environmental
              Impact
              Statement
                       •

              City of Anchorage, Alaska
              Wastewater Facilities

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           ADDENDUM/FINAL
     ENVIRONMENTAL IMPACT REPORT
      MUNICIPALITY OF ANCHORAGE
    SEWERAGE FACILITIES EXPANSION
            Prepared by:

U. S. Environmental Protection Agency
              Region 10
          1200 Sixth Avenue
         Seattle, WA   98101
    Clark Smith, Project Officer
   With Technical Assistance from:

   Jones & Stokes Associates, Inc.
            2321 P Street
        Sacramento, CA 95816
              June 1983


        Responsible Official
            L. Edwin Coate
    Acting Regional Administrator
   Environmental Protection Agency
              Region 10

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                         COVER SHEET
               ADDENDUM/FINAL IMPACT STATEMENT
                      EPA-910/9-82-091


a)  Lead Agency:  Environmental Protection Agency.

b)  Proposed Action:  Expansion of Municipality of Anchorage
    Wastewater Facilities.

c)  For further information contact:

        Mr. Clark Smith, Project Officer
        U. S. Environmental Protection Agency
        Region 10
        1200 Sixth Avenue, M/S 443
        Seattle, Washington  98101

    To request copies of the Addendum/Final EIS contact Mr.  Clark
    Smith at the address noted above.

d)  Designation:  Addendum/Final EIS.

e)  Abstract:  A Draft EIS for expansion of Municipality of
    Anchorage wastewater facilities was prepared and made available
    for public review in January 1983.  Six comment letters  were
    received.  Consideration of these comment letters in preparing
    the Final EIS required only minor changes to the Draft EIS.
    The changes to the Draft EIS, the comment letters,  and responses
    to the letters are contained in this addendum.  This addendum
    and the Draft EIS constitute the Final EIS.

    The proposed action is the expansion of the Point Woronzof
    Wastewater Treatment Plant from 34 to 58 MGD, extension  of the
    outfall, adding an outfall diffuser, solids disposal, con-
    struction of two major interceptor sewers, and designation
    of rural Hillside areas for on-site sewerage or public sewer
    services.  The EIS discusses the impacts of these proposed
    actions and alternatives with emphasis on wetland impacts,
    Hillside area issues, effluent disposal issues, and secondary
    impacts.  Specific mitigation measures in the form of
    proposed grant conditions are considered.

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                      EXECUTIVE SUMMARY
           ADDENDUM/ENVIRONMENTAL  IMPACT  STATEMENT
Draft  ( )
Final  (X)
Prepared by:     U. S. Environmental Protection Agency
                 Region 10
                 1200 Sixth Avenue
                 Seattle, WA  98101

Type of Action:  Administrative


                     Project Description

     This Final Environmental Impact Statement  (FEIS) is
prepared by the U. S. Environmental Protection Agency (EPA)
to evaluate the impacts of expanding the Municipality of
Anchorage  (MOA) wastewater collection, treatment and dis-
posal system.  This Addendum and the Draft Environmental
Impact Statement (DEIS)  constitute the FEIS.

     The FEIS specifically evaluates the MOA facilities plan
that proposes expansion of the sewerage system.  That facili-
ties plan consists of two related documents.  The first is
entitled Wastewater Facilities Plan for .Anchorage, Alaska
dated June 1982.  This report was prepared for the MOA
by a joint venture of Ott Water Engineers, Inc., Quadra
Engineering, Inc., and Black and Veatch Consulting Engineers,
and it comprises the majority of the MOA Section 201 facili-
ties plan.  The remainder of the Section 201 facilities plan
is the Hillside Wastewater Management Plan developed by the
MOA Planning Department, with contract assistance from Arctic
Environmental Engineers and adopted by MOA in May 1982.

     The Hillside Wastewater Management Plan, funded under
Section 208 of the Clean Water Act, was prepared to address
sewerage needs of the Hillside area of the Anchorage Bowl
with an emphasis on continuing on-site sewage disposal and
preserving a rural lifestyle in the study area.  The plan
identifies areas of the Hillside that are to be served by
on-site treatment and disposal systems (such as septic tanks
with drain fields), areas to be served by sewers, and areas
unsuitable for on-site systems where no sewer systems are
to be provided  (although on-site systems may be allowed).

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     The Wastewater Facilities Plan for Anchorage.  Alaska
(MOA 1982)  recognizes the determinations for these Hillside
areas and proposes sewage collection, treatment and disposal
systems serving the areas designated for sewerage in the
Hillside plan.  It also encompasses alternatives for expansion
of sewage collection, treatment and disposal facilities for
the rest of the Anchorage Bowl, outlined as follows:

     o  Alternatives for expansion of Point Woronzof waste-
        water treatment plant  (WWTP) from a current design
        capacity of 34 MGD to  58 MGD.

     o  Extension of the existing outfall by 1,500 feet.

     o  Adding a diffuser of undetermined length at the
        end of the extended outfall.

     o  Alternatives for disposal of sludge solids from
        the treatment process.

     o  Alternatives for construction of the West Bypass
        Interceptor sewer.

     o  Construction of the Southeast Interceptor sewer,
        including sewerage alternatives in the Rabbit Creek-
        Potter Creek area.

     o  Provisions for on-site sewerage of a portion of the
        Hillside area.

     o  Construction of about  70 sewer improvement projects
        through 1998.

The facilities plan also sets  forth a MOA-Recommended Plan,
suggesting implementation of specific alternatives.

     For EIS purposes the above project alternatives, except
for the 70 sewer improvement projects, are evaluated in de-
tail in the EIS.  The 70 sewer improvement projects are
addressed only with specific reference to wetland impacts
and in general terms relative to cumulative impacts.


Recommended Plan

     The Point Woronzof WWTP would be expanded from its
current effective capacity of 22 MGD to 58 MGD (average annual
flow).   Current design capacity is 34 MGD, although the plant
cannot meet discharge requirements at a design flow rate
over 22 MGD.   This expansion would be achieved through con-
struction of  three additional primary clarifiers, modification
                               11

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of other portions of the liquid processing to increase capa-
city, addition of another sludge incinerator to the solids
process, and consideration of alternative disposal methods
for incinerator ash.  The facilities plan indicates a pre-
ference for discharging the ash into the Knik Arm of Cook
Inlet through the outfall along with the effluent, although
discharge to a landfill or to lagoons or a gravel pit in
the area of Point*Woronzof is also considered.

     The facilities plan recommends that the outfall be ex-
tended by 1,500 feet, that an extensive design effort be
undertaken, and that the diffuser requirements be further
studied.  Preliminary diffuser modeling prepared for a
Section 301(h) waiver application determined that a 1,000-
foot diffuser would enable the discharge of chlorinated
effluent to meet all existing water quality standards.

     A diffuser study is underway to evaluate outfall and
diffuser requirements under the assumption that chlorination
would be discontinued.  Preliminary results indicate that
a theoretical diffuser length of tens of miles .would be needed
to meet coliform standards applicable to Cook Inlet if
chlorination is discontinued.  All other standards, however,
apparently could be met with a minimal  (100-foot) diffuser.

     The study also is evaluating the diffuser requirements
under assumptions that certain state-designated beneficial
uses of the waters of Cook Inlet would be deleted.  This
change would allow less strict Alaska state water quality
standards to apply.  If fecal coliform standards of 200
FC/100 ml were to apply (compared to current standards of
14 FC/100 ml), a diffuser length of 6,100 feet would enable
the discharge to meet this standard.  If designated uses
were further relaxed to eliminate all coliform standards
a minimal length  (100-foot) diffuser would be adequate.

     A major interceptor sewer, the West Bypass Interceptor,
is proposed to connect existing interceptor sewers at the
Alaska Railroad crossing over Campbell Creek to an existing
downstream section of the West Bypass Interceptor sewer near
the Minnesota Bypass-Raspberry Road intersection.  The pro-
posed completion of the interceptor between these points
would bypass a deteriorated, undersized corrugated metal
pipe sewer paralleling Campbell Creek and an occasionally
overloaded pumping station at Campbell Creek.

     The existing Southeast Interceptor is proposed to be
extended south to provide service to areas of the Hillside
that are designated for public sewerage in the Hillside plan,
including the south Hillside areas near Potter Creek and
Rabbit Creek.
                                111

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     The Hillside Wastewater Management Plan (MOA 1982)
evaluated the suitability of the Hillside area of Anchorage
to accommodate on-site disposal systems, arid delineated areas
for public sewers, unsewered areas for on-site systems and
unsewered areas generally unsuitable for on-site disposal
systems.  It sets forth planning and design criteria, con-
struction guidelines and operation and maintenance require-
ments for on-site systems.

     The Hillside plan does not preclude on-site systems
in generally unsuitable areas; rather it applies additional
restrictions, including soil tests for each Ipt in a  sub-
division, requiring innovative systems unless conventional
systems are shown to be acceptable, and requiring more detailed
system reviews by MOA.

     The existing Anchorage Bowl system of collector  sewers
is in need of expansion, replacement and renovation in certain
areas.  Additional capacity is required in some instances,
as well as replacement of several miles of corrugated pipe.
About 70 sewer construction, rehabilitation and replacement
projects are recommended in the facilities plan.
 Alternatives

      The  DEIS  evaluates  alternatives to the Recommended  Plan,
 including no action.  The Executive Summary in the DEIS  sum-
 marizes those  evaluations.
                     Environmental Impacts

      The  DEIS  evaluates environmental impacts on cost, wet-
 lands,  the  Hillside  area, and cultural resources; secondary
 impacts on  services  and utilities, natural resources, and
 socioeconomic  values; treatment and disposal impacts; sludge
 processing  and disposal impacts; and construction impacts.


                      Proposed EPA Action

      EPA  proposes  to provide federal grant funding,  subject
 to  available funds and appropriate application by the MOA,
 for the following  project elements:

      o  Expansion  of the Point Woronzof WWTP to 58 MGD.
      o  Extension  of the existing outfall by 1,500 feet.
      o  Addition of  a diffuser when the appropriate  length
        is  determined.
                                IV

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     o  Construction of the West Bypass Interceptor sewer
        by tunnel construction.

     EPA proposes to impose grant conditions on the MOA
requiring monitoring of surface water quality and ground-
water quality in the Hillside area as mitigation measures.
                         Conclusions

     The distribution list for the DEIS and this FEIS is
included at the end of the report.  Availability of the FEIS
should be announced in the Federal Register in May 1983.
Comments are invited, and should be directed to:

     Mr. Clark Smith, Project Officer
     U. S. Environmental Protection Agency
     Region 10
     1200 Sixth Avenue, M/S 443
     Seattle, Washington  98101

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                       TABLE OF CONTENTS
CHAPTER 1 - INTRODUCTION

CHAPTER 2 - COMMENT LETTERS AND RESPONSES                  3
     Response to Comments by Homeowners and Land-          7
      owners Organization, Inc.  (HALO)
     Response to Comments by Alaska Department            14
      of Fish and Game
     Response to Comments by Kathryn Reed                 17
     Response to Comments by R. Brock Shamberg,           20
      P.C., Attorneys at Law
     Response to Comments by Rabbit Creek                 24
      Community Council
     Response to Comments by U.S. Fish and                27
      Wildlife Service

CHAPTER 3 - CHANGES AND CORRECTIONS TO DEIS               29
     Revisions to Page viii                               30
     Revisions to Page 34                                 31
     Revisions to Page 36                                 32
     Revisions to Page 153                                35
     Explanation of Figure 8-5, page 181                  36
     Revisions to Page 213                                38

CHAPTER 4 - DISTRIBUTION LIST, NOTIFICATION LIST          39

REFERENCES                                                48

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                          Chapter 1
                        INTRODUCTION
     This addendum to the Draft Environmental Impact Statement
(DEIS) for the Municipality of Anchorage wastewater facilities
contains the public comments received on the draft statement,
responses to the issues raised and changes or corrections
to the draft statement.  Since textual changes to the DEIS
are minor, changes have been noted on errata sheets contained
in this document.  This is consistent with part 1503.4 (c)
of the Council on Environmental Quality Regulations for Implemen-
tation of the Procedural Provisions of the National Environmental
Policy Act (NEPA).  This document, combined with the DEIS,
represents the Final EIS, and has been filed with the Council
on Environmental Quality.

     No comments raised issues that warranted the modification
of alternatives evaluated, the addition of new alternatives,
or additional environmental analyses.

     Some comments raised issues which were beyond the scope
of the DEIS or requested information already addressed in
the draft statement.  In these cases, the commentor was referred
to the appropriate section (s) of the DEIS for this information.
Brief statements were also made which specifically responded
to the comment.  In a few cases, comments were raised which
required changes to be noted to correct textual errors,  add
new information, or to clarify text.  In these cases, the
response notes that changes are reflected in the errata sheets.
The preparers of the statement also noted some minor textual
errors which are also reflected by changes on the errata sheets.

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                          Chapter 2


                COMMENT LETTERS AND RESPONSES


     This section contains reproductions of the comment letters
received and provides responses to the issues raised.  These
letters are listed below:

     1.  Homeowners and Landowners Organization, Inc. (HALO);

     2.  Alaska Department of Fish and Game (ADFG);

     3.  Katherine M. Reed;

     4.  R. Brock Shamberg, P. C., Attorneys at Law;

     5.  Rabbit Creek Community Council;

     6.  U. S. Fish and Wildlife Service.

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                                                                           :''-~"1~'":r. .'H!
                                                                                - !-•-•; i H
                    ^omeowners
                    (\nd
                      andowners
                     ]rganization,  Inc.

                                                                       ••• ry,vjJAT10N
                                       P.O.  Box 10-2022
                                       Anchorage, AK  99511
       Mr. Clark Smith
       Project Officer
       U.S. Environmental Protection Agency
       Region  10
       1200 Sixth Avenue
       Seattle, WA  98101

       Subject:  Draft E19 - City of Anchorage,  Alaska;  Wastewater Facilities,
                 December 2, 1982.
2.
3
4
 Dear Mr.  Smith:

     The  following comments are supplemental to the testimony given by HALO
 and others during the previous public hearings for both the EIS and the
 Hillside  Waste Water Study.  HALO is an organization of Hillside home and land
 owners  among whose purposes are to inquire into matters of community impor-
 tance and to defend the communities unique heritage of a largely natural pure
 and healthful environment.  Our comments are limited to the impacts on the
 Hillside  of the Southeast Interceptor.

     In our opinion the draft EIS does  not meet the full disclosure provisions
mandated  by the regulations of the Council on Environmental Quality.  We are
 particularly concerned that long term and cumulative adverse impacts of the
 proposed Southeast Interceptor Extension are not adequately described.  In our
opinion several of the assumptions on which the EIS is based are non-factual,
and cannot be supported.   We believe the deficiencies are of such magnitude
the impact statement sections pertaining to the South Interceptor Extension
should be revised and another opportunity for public review provided.

Specific comments follow:
       1.    The objectives of the facilities  plan as  provided on page 3 are not
            sufficient.  Page xii of the  Executive Summary discusses the limited
            supply of water on the hillside and  acknowledges  this may either be a
            limit on development or a requirement that  a public water be provided
            from an external source.   The  objectives  of page  3 investigate  the
            ability of the proposed wastewater collection systems ability to meet
            anticipated  loads without consideration of  the limitation on these  loads

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            imposed  by  water availability.   If  the EIS  is to be realistic  it should
            address  the capacity,  cost  and  impacts of sewers as limited  by present
            water  availability.   If  the EIS  is  to  address sewers to accommodate the
            postulated  population density they  should include the costs  and environ-
            mental impact  of the  necessary  public  water system in the  EIS.   To  not do
            so  is  misleading the  public.

            The safe Drinking Water  Act described  on page 9 is not being complied
            with.  The  dense developments projected for the lower hillside can  not be
            served by ground water.  Approved"new  subdivisions (South  Addition  No. 4)
            are obtaining  surface water through infiltration galleries from Little
            Rabbit Creek.   High nitrate levels  have been observed in this  stream
            (page  139)  and higher levels may be expected.   The EIS does  not accommo-
            date the health hazards  imposed  by  the dense development.  The EIS  does
            not recognize  the cost nor  environmental impact of works or  political
            restraints  necessary  to  control  nitrates in surface waters used for
            domestic water supply.

            The population projections  given in table 1-1  for the year 2000,  on which
            the wastewa:ter treatment needs  are  based, are  about 25 to  30 percent high
            as  compared to more recent  projections.

 O  I   4.    The description of fish  species  utilizing Rabbit Creek given on page 121
    I        should include King Salmon.

       5.    The section on page 132  and 133, Impacts on Potter Marsh fails  to discuss
            impacts  resulting from breaks and repair of the proposed interceptor.
            The section should also  identify impacts resulting from failure of  lift
            stations during power outages and the  expected frequency of  these out-
            ages.  The  discussion of impacts should  also include  a discussion of the
            impacts  from cleanup  of  raw wastewater in Potter Marsh.  This  section is
            also deficient in discussion of  cumulative  impacts of  proposed  works.

       6.    The discussion of water  availability,  impacts  of the  proposed wastewater
I r\          system,  and dense population postulated  does not in our opinion meet the
'            full disclosure requirements of  the  NEPA.   The impact  statement should
            discuss  fully  the necessary works to provide domestic  water and their
            costs  and impacts.  We are  particularly  concerned the  analysis  should
            consider impacts on areas outside of the immediate area served  by sewers.

       7-    The statement  on page  156,  "areas south  of  Little Rabbit Creek  cannot
            develop  until  the South  East Interceptor is  extended..." i-s false and
 //          misleading.  The area  can and is being developed under existing laws,
            regulations  and  zoning.  The only constraint is  its  inability  to support
            the population density desired by developers.   Other  similar misleading
            statements  exist.

       8.    Table  7-1 is misleading  in  that  much of  the  Hillside  land  described  as
 \2.         available is not  developable because of  problems such  as ground water,
            slope  instability and wind  loading.

       9.    The  EIS  has not  adequately  considered  the effects  of  seismic events  on
/3          tne  South East  Interceptor.  The analysis should include the effects of
            slope  instability under  seismic  excitation.

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     Ue in HALO are willing to consult with you towards resolving  the
deficient portions of your document.

                                       Respectfully Yours,
                                       Giles N. McDonald
                                       President HALO

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Response to Comments by Homeowners and Landowners Organization,
Inc. (HALO)

1.  HALO comments that the DEIS does not meet the full disclosure
    provisions of the regulations promulgated by the federal
    Council on Environmental Quality.  Throughout the EIS
    process EPA has pursued full disclosure of all impacts,
    and has provided numerous opportunities for public input
    to facilitate that disclosure.  The responses to the specific
    comments of HALO and other commentors is another step in that
    disclosure process.

2.  The DEIS addresses long-term and cumulative impacts of the
    southeast interceptor in Chapters 4, 5, and 7;  Additional
    information is contained in the responses to comments in
    this FEIS.

3.  HALO suggests the DEIS relied on nonfactual assumptions.  The
    DEIS relied on facts available to EPA through local, state,
    and federal agencies, relevant literature, public input, and
    field review.  We have responded to each concern of HALO,
    relying on the best information available to us.

4.  Further public review is afforded through issuance of this
    FEIS.  A 30-day public review period begins on the date that
    the official Federal Register notice is published announcing
    availability of this FEIS.

5.  The objectives of the Facilities Plan are set forth in that
    plan, and are summarized on Page 3 of the EIS.  The objectives
    of the Facilities Plan are adequate and acceptable to EPA
    under the Clean Water Act and regulations adopted by EPA
    pursuant to the Act.  While grant funding may be provided by
    EPA for sewerage facilities, the Clean Water Act provides no
    authority for the planning of public water supply systems.
    The DEIS recognizes the relationship between water supply and
    sewage generation  (page 160, paragraph 4, specifically, and
    pages 159 and 160, more generally).  The DEIS also recognizes
    (pages 209 and 210)- that the water scarcity problem is not
    resolved in the EIS and is, in fact, beyond the scope of the
    EIS to resolve.  Planning efforts outside the scope of 201
    planning will be required to resolve the water problem.  The
    EIS assumes that the water shortage will be resolved.  Current
    water supply augmentation efforts of the MOA  (DEIS, page 160)
    reinforce this view.  It should be recognized, however, that
    if supplemental water supply sources are not developed, growth
    may be constrained, and wastewater volumes may not be as
    large as expected.  It is also possible that additional growth
    pressure may be felt in the Hillside area and other areas
    where public water supplies are not currently prerequisites
    for development.

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It is not within the scope of the EIS or the Facilities
Plan to estimate the maximum quantity of sewage that could
be generated by the area's current limited water supply.
Similarly, it is not in the scope of either document to
identify or evaluate the sewerage facilities that would be
required to collect, treat, and dispose of such limited
sewage quantities.

The Safe Drinking Water Act, which became law on December 16,
1974, was enacted to assure that the public is provided with
safe drinking water.  It applies to all community water
supplies, both government- and investor-owned, that have 15
or more service connections, or that serve 25 or more
individuals.  The Act does not apply to the individual wells
that serve one or two homes in the Hillside area.  It does
apply to individual wells that serve schools and restaurants,
as well as to community water systems meeting the above
criteria.

In general, the law calls for the federal government, through
EPA, to establish standards for drinking water quality, and
for  the  state governments to enforce the federal or more
stringent  state standards.  The State of Alaska has assumed
responsibility for enforcement of the federal standards and
certain more stringent state standards.  The state standards
include bacteriological standards, violations of which may
occur in Little Rabbit Creek, as well as other area streams.
State statutes also charge the Alaska Department of Environ-
mental Conservation  (ADEC) with the conservation and protec-
tion of water resources.

Nitrate is the primary inorganic constituent of concern in
the Hillside area, due to the potential for elevated nitrate
levels from septic system discharges.  Monitoring of surface
water in Little Rabbit Creek (USGS 1975, 1982) has detected
no violations of the EPA-established maximum contaminant
level of 10 mg/1 nitrate as N.   The highest level detected
in the USGS sampling was 4.6 mg/1 in 1967.  Sampling in 1979
and 1980 showed nitrate levels of less than 1 mg/1.  Page 139
of the DEIS does not refer to high nitrate levels in any
local streams.

However, as cited on page 140 of the DEIS, nitrate levels
near to EPA standards have been detected in some individual
wells.   The Hillside Plan element of the Facilities Plan may
not adequately protect groundwater quality in the Hillside
area, where groundwater is the major source of drinking water,
because large areas of the Hillside area remain designated
for on-site sewerage systems.  Studies of groundwater re-
sources in the Hillside area demonstrate that drinking water
quality standards already are threatened by on-site disposal
systems,  and would be increasingly jeopardized by projected
population growth in the area if on-site disposal remains as
the major wastewater treatment system.   Threats to surface
water from on-site system discharges may also increase.

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    The DEIS recognizes these potential threats to public health.
    EPA will impose grant conditions on the MOA to require
    regular monitoring of groundwater and surface water.

    The EIS does address the health hazards imposed by develop-
    ment pursuant to the Hillside Wastewater Management Plan,
    primarily in Chapter 5.  It is beyond the EIS scope to
    develop cost estimates for implementation of adequate
    methods that would prevent nitrate contamination of water
    supply sources.  The DEIS recognizes the potential for
    contamination to occur and suggests steps that can be
    taken to prevent public health threats from developing.
    The cost and impact of prevention will increase with time,
    and the cost and impacts of remedies after contamination
    has occurred may be substantial.  The MOA can estimate
    the costs of incorporating additional preventive measures
    in their Hillside area management program, since implemen-
    tation is a local responsibility.  However, estimation
    of costs and impacts of actions that are not part of the
    Facilities Plan are beyond the scope of this EIS.

7.  The population projections used in the Facilities Plan
    and the EIS were developed by MOA and used consistently
    in the planning process.  Table 1-1 on page 14 of the
    DEIS cites projections developed by the Institute for
    Social and Economic Research, adopted for use by the MOA
    for development of the Comprehensive Plan.  Any projections
    are subject to revision.  Such a revision would  indicate
    an expected change in growth rate, which would be translated
    into a change in the rate of increase in sewage flows.

8.  King salmon may occur in Rabbit Creek in relatively small
    numbers.

9.  If sewage were to be accidentally discharged in large quanti-
    ties to Potter Marsh, effects could result from the increased
    BOD load, toxicants in the wastewater, and elevated nutrient
    levels.  High BOD resulting from accidental discharge of large
    quantities of sewage could substantially depress the DO level
    in the marsh to the point of jeopardizing aquatic species.
    Since most of the wastewater expected to be generated in the
    area near Potter Marsh is domestic waste,  no quantities of
    toxic or hazardous substances are expected to be present.

    Potter Marsh is separated from Turnagain Arm by tidal gates
    on Rabbit Creek as it passes under the Alaska Railroad.  Tidal
    flushing is restricted, and it would appear that the residence
    time of any spill and the subsequent flushing rate would be
    dependent on the flow of Rabbit Creek.

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     Tertiary treatment of sewage has been frequently mentioned
     as a beneficial value of wetlands because it is assumed that
     marsh plants would take up nutrients from the wastewater
     stream.  Gosselink et al. (1973) went so far as to calculate
     an economic value for wetlands based on tertiary treatment
     capability per acre.  A rigorous review of extant salt marsh
     literature  (Nixon 1980) has challenged the notion that salt
     marshes are capable of "treating" wastewater.  It would
     appear that the necessary data to support early claims for
     this beneficial use did not exist.  Furthermore, efforts to
     experimentally determine whether wetlands can treat sewage
     have been equivocal in their results.  It would appear that
     the ability to take up nutrients varies widely from place to
     place and perhaps seasonally as well (Nixon 1980).  A pre-
     liminary study conducted by Schwartz (1982)  on a northern
     freshwater marsh indicates that excessive nutrients and a
     large carbon source result in high phytoplankton productivity
     and bacterial growth.  These, coupled with high particulate
     matter, inhibit submergent vegetation growth and invertebrate
     fauna diversity, thereby increasing downstream transport of
     nutrients.  An experimental nutrient enrichment study on
     an Alaskan bog  (Sanville 1981) suggested that nutrients would
     be absorbed by sphagnum bogs.  However, the experiment
     examined only plant productivity and occurred in a wetland
     habitat which is different from Potter Marsh and known to be
     typically nutrient-deficient.

 10.  The purpose of the EIS is to evaluate sewerage projects,
     rather than water supply projects.  No water supply projects
     are proposed as part of the Facilities Plan.  The DEIS
     does recognize that development of the Hillside area with
     on-site sewers may lead to well contamination, and that
     a possible mitigation measure is to provide a public water
     supply system to the Hillside.  The third paragraph on
     page 151 of the DEIS discusses this possible mitigation
     measure briefly.

     Implementation of such a system would require a series
     of booster pumps, reservoirs, and pipelines.  Construction
     could be noisy and disruptive; erosion may occur in con-
     struction areas, adversely affecting water quality; reservoirs
     may cause adverse visual impacts; pump stations could
     produce intermittent low-level noise; and a water system
     could induce additional growth pressure on the Hillside
     Area.   Analysis of these impacts is beyond the scope of
     the EIS,  since EPA has no plans to require a water system
     as a mitigation measure, nor would such a project qualify
     for Clean Water Act grant funding.

11.   The DEIS  assumes that the area south of Little Rabbit
     Creek cannot develop at the densities indicated in the
     Comprehensive Plan until public sewer service is provided.
     The southeast interceptor extension is recommended in
                                10

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     the Facilities Plan as the preferred method for providing
     the sewerage.  The intent of the statement on Page 156
     is to illustrate the growth-inducing effect of this portion
     of the proposed sewerage facilities.

12.   HALO suggests that Table 7-1 is unrealistic, due to natural
     constraints on development in the Hillside area.  Table
     7-1 is drawn directly from the Hillside Wastewater Management
     Technical Report... (MOA 1982), Table 4-2 on page 34.
     The text accompanying the table recognizes that environ-
     mental constraints limit development, but that, "where
     natural environmental features are unconducive to develop-
     ment, specific measures can be taken to provide adequate
     housing.  But, it inevitably requires a higher cost."

      The Hillside Wastewater Management Plan does not designate
     areas undevelopable for reasons cited by HALO.  Construc-
     tion techniques are available to allow construction on
     difficult sites, including areas of high groundwater (elevat-
     ing structures, providing drains), slope instability (retain-
     ing walls, pilings), and wind loading (designed to resist
     predicted wind  forces).

     The figures for Hillside area population are explained
     (ibid., page 39) as representing "...an unspecified future
     saturation development condition where all developable
     land has been utilized in some manner."

     No estimate is given,  either in the Hillside Plan documents
     or the DEIS, as to when this saturation development would
     occur.  EPA does not believe that republication of the
     estimates developed in local planning activities is
     misleading.

13.   Seismic activity can have devastating effects on natural
     and human-made features, as was amply demonstrated by
     the 1964 earthquake.  Sewer lines are susceptible to joint
     separation, severance of lines, both vertically and horizon-
     tally, and stations can be heavily damaged.   As described
     on page 143 of the EIS, the sewer system could be disabled
     for an extended period.  A further discussion of these
     impacts is presented in previous response number 9.
                                11

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 crzi
                                                        BILL SHEFFIELD. GOVEFt.'-'OR
 March  11,  1983
 Environmental Evaluation Branch
 U.S.  Environmental Protection Agency, Region 10
 1200  Sixth Avenue, ll/S 443
 Seattle, Washington 98101

 Attention:  Mr. Clark Smith

 Gentlemen:

 Re:   Agency Review - Draft Environmental  Impact Statement  (DEIS)
      City  of  Anchorage Wastewater Treatment Plant Expansion and
      Facilities.
Proposed
Interceptor
 The  Alaska  Department of Fish  and  Game (ADF&G) has  reviewed  the Draft  En-
 vironmental  Impact  Statement referenced above.  The  ADF&G finds this  docu-
 ment  a  clear and  concise description of the environmental conditions  occur-
 ring  within the  project  area.   The  analysis  of the  recommended plan  ade-
 quately  addresses  the potential impacts resulting  from project  implementa-
 tion.  As described, the project is  considered  consistent with the Standards
 of the Alaska Coastal Management Plan.

 A  major concern  of  this Department centers on  the  proposed  location  and
 design  of  a pump  station  to be  located  near  Rabbit  Creek  at  one  of  two
 possible  locations:   a)   between  Old  and  New Seward Highways,  north  of
 Potter Marsh,  or  b)  adjacent  to  the  Old  Seward  Highway north of  Rabbit
 Creek.   The ADF&G  recommends  the   final  design  and  siting  of  this  pump
 station provide adequate protection  for the  Potter Point State Game Refuge.
 Feasibility  and design  of  bypass  and  containment  facilities  should  be  an
 integral   part   of   the   planning   and   design    phase   of   the    Rabbit
Creek  area   collection  system.    These   facilities  should  be  designed  and
located to  avoid  Potter Point  State Game Refuge  and  to  avoid  disposal  of
                                                                             " ! n'
                                                                             L-.ii 'I
                                     12

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C. Smith                             -2-               March n, 1933

wastew£.ter  into  Rabbit  Creek.   Please contact  Mr.  Gary  Liepitz,  Habitat
Division, Anchorage  at  267-2281  if you have  any  questions concerning this
project.

Sincerely,

Don W. Collinsworth, Commissioner

            0-

BYrPhilip 0.  Brna
   •  Habitat Biologist
     Habitat Division
     (907) 267-2284

cc:  D. Harkness, ADF&G
     B. Martin, DEC
     B. Lawrence, EPA
     B. Bowker, USFWS
     P. Wohl, MOA
     W. Wolf, DPDP
                                     13

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Response to Comments by Alaska Department of FishanH Game

1.   Comments acknowledged.  EPA will require the engineering
evaluation of bypass and/or containment facilities in the
Rabbit Creek area as a part of any Clean Water Grant for the
Rabbit Creek facilities.  Also, see responses to comments
by HALO, Inc.
                              14

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                                                                     P.  O.  Box 110204
                                                                     Anchorage,  AK 99511
                                                                     March  3,  1983
 Mr. Clark  Smith, Project Officer
 U.S. Environmental Protection  Agency
 Region  10
 1200 Sixth Ave., MS 443
 Seattle, WA 98101
 Dear Mr.  Smith:

     The  following comments are  in  reference to the DEIS, City of Anchorage,
 Alaska, Waste Water Facilities,  with particular emphasis on the Hillside
 area.

     I belisve it should be stressed that it will be possible to accommodate
 a considerable increase in population in the Hillside area under the scheme
 proposed  by the Wastewater Management Plan without extending sewers beyond the
 areas recommended for public sewers.  The enforcement of complete site testing
 (to include identification of the water table positions at the three septic
 system sites per lot), thorough  inspection of installations, and aggressive
 maintenance of system should be  sufficient to ensure safe continuation of the
 various lifestyles in the area.  Until the MOA actively insists that pumpers
 have proper tank-cleaning (not just emptying) equipment, encourages/approves
 use of the mound and shallow trench systems, and knows conditions in undeveloped
 areas well enought to require safe  lot configuration even at the expense of
 replatting to larger lots, then  we risk continuing the present less-than-optimum
 conditions.

     The  USGS "Hillside" report  does not recommend surface water as a source for
 drinking  water.  Hydropraphs will show that flow is probably inadequate,
 especially in winter, for any concerted development, quite aside from the water
 quality problems.  The impact on Potter Marsh will certainly be adverse if
 the creeks are tapped.

     With increased runoff that  normally follows development,  it will be
 essential to identify flood-plain dimensions and see that creekside land is
 in a condition to withstand floods. The MOA has never addressed the cause and
 effects of the periodic late spring flooding on Rabbit Creek—a problem that
may well be compounded by increased suburban runoff.  The MOA  is,  however,
working on a plan to retain much of Rabbit Creek's course in its natural
state.

     The limiting factor on Hillside population growth is bound to be water
availability.   There is not sifficient data to predict the location of
suitable aquifers in the glacial sediments—nor is there likely to be.   If
the water budget is upset by bringing coTimunity water to the area and
recharging it through septic systems or by draining the area by sewers,
the consequences will be dire indeed.   Therefore,  I do not think it can
                                         15

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be stressed too much that planning for sewers anywhere in the Hillside has to
be done in concert with planning for water supplies.  Recommendations in the
DEIS need to deal with this perhaps more explicitly.

     The sewer line route near Potter Marsh might cause fewest problems if
it were routed as in alternative 3 (p. 67) with plan D.  Potter Marsh has too
great a value to the city to be compromised by the chance of leaks or breaks
in sewer lines.  The backup pump and storage alluded to would be valuable.

     Sewer sizing should not encourage additions from the Hillside, as the
addition is almost certain to be random, a reaction.  I think it is possible
to rehabilitate failed systems by re-location or other means, even if the
homeowner is inconvenienced for some time. (The spectre of this failure
ought to prompt good maintenance;  it should also spur the MOA into insisting
on adequate tank-cleaning equipment.,

     Final1, one of the secondary impacts of Hillside growth will be the need
for additional paramedics.  This item ought to be added to the list in the
DEIS.

                                                  Sincerely,
                                                  Katherine M. Reed
                                        16

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Response to Comments by Kathryn Reed

1.  This comment is generally consistent with the findings
    of the EIS.  EPA also believes that monitoring of ground-
    water and surface water is essential to detecting increases
    in nitrate levels and other contaminants and is also essential
    to protecting public health.

2.  The USGS  (1975) concludes that:  "Surface-water reservoirs
    or diversions from the streams crossing the area do not
    appear to be practical sources of water."  However, during
    the EIS process it was brought out that developers were
    proposing to provide a water supply from streams in the
    Hillside area.  Since the availability of sewers to the
    south Hillside is viewed as a growth-inducing factor,
    and the impact of depleting the surface-water supply to
    Potter Marsh thereby became an EIS issue, the DEIS addresses
    this issue.

3.  Comment acknowledged.

4.  The suggestion that water and sewer facilities must be
    evaluated in concert to avoid disruption of local groundwater
    hydrology is sound.  However, as discussed in prior responses,
    the purpose of the DEIS is to evaluate the impact of sewerage
    decisions, rather than water supply decisions.  The EPA
    hopes that the MOA will include both water and sewerage
    considerations in future planning for the Hillside.  This
    is particularly important if future groundwater pollution
    prompts the introduction of a community water system as
    a mitigation measure.  The addition of an unconstrained
    water supply concurrent with cessation of current groundwater
    pumping may lead to substantial increases in local and
    seasonal groundwater levels, with adverse effects on the
    ability of septic systems to provide adequate treatment.
    This in turn could threaten public health due to surfacing
    of inadequately treated effluent.

5.  Comment acknowledged.

6.  Comment acknowledged.

7.  Comment acknowledged.  Paramedic services, ambulance service,
    hospital facilities,  and other types of health care services
    will all be affected by growth.
                               17

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                     R. BROCK SRAMBERG, P. C.
                           ATTORNEYS AT LAW
BROCK SMi-'BSRG                POST OFFICE BOX 1O-295
                        ANCHORAGE, ALASKA O9511
                         TELEPHONE (907)345-3855



                                 March  4,  1983
 Mr. Clark Smith
 Environmental Evaluation Branch
 Environmental Protection Agency,  Region 10
 1200 Sixth Avenue, M/S  443
 Seattle, WA  98101

 Re: EIS Anchorage Wastewater  Facilities;  Draft, November 1982

 Dear Mr. Smith:

      I  have  read with  interest  and  concern  the  Environmental
 Impact  Statement  for  the Anchorage  wastewater  facilities   and
 appreciate this  opportunity to  respond  to the draft.

      Overall,  I  am  struck  by  the tremendous  amount  of effort  and
 work  that  has gone  into  the  Environmental  Impact Statement,  but
 keep  coming  back  to one  central question.   What  about on-site
 disposal  systems?   Why does the report  seem to play  down this
 permanant solution?

      I  realize,  of  course, that  the  impact  statement is a  feasi-
 bility  study,  as opposed  to  recommendation  for  construction,  but
 it  is  clear in  the  overall  reading  of  the  report  that a major
 permanent  solution   for many  of  the  hillside residents  has been
 mainly  ignored,  obscured  or  played  down.  My  feelings  and reac-
 tions can be simply  stated as follows:

      1.  The report  is  comprehensive, but fails to adquately deal
 with  an on-site  development  program  that  would  include   proper
 construction,  operation and  maintenance  of  existing  and   future
 on-site septic systems.

      2.  Cost  comparisons  are  not  adequately  stated with  regard
 to alternatives  of   spreading  the effective  costs of  sewer con-
 struction vs. on-site systems.

      3.  Anchorage is not  a community that needs a massive, long-
 term construction project  to  boost  its  economic base, and  if such
 a  project were needed,  the "Knik Crossing"  would  serve  the needs
 of the community far better.

      4.  The report  ignores the  current problems with the current
 city  sewer  system and the  upgrading of  those lines and facilities
 that  are of  mounting proportion.
                                 18

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    '•'i . '..'i. ar:k Srrii th
    Page Two
    March 4, 1983
7
8
     5.  The  report  does not  adquately  consider nor  provide  for
surface  water  conditions  on  the  Hillside, despite  its being  a
high priority at the EIS scoping meetings.

     6.  Although availability of  water  for  Hillside  residents is
of  equal concern, whether  there  is  a sewer  system  or  a  septic
system,  the report does  not deal with  this  problem  in an adequate
manner,  nor in the long  range.  This  is  the priority  issue, in my
opinion, and  wastewater  a  secondary and a  far  less  limiting fac-
tor to our growth and quality  of life.

     Overall, the report lacks because of what is omitted;  not in
what  is  stated.   Everyone realizes  that  sewers are  a  necessity
and an  inevitability  in certain  areas,  but  recommendations  are
strongly needed with regard to the proper construction,  operation
and maintenance  of  on-site  syterns  where   possible.    This  the
report  simply  does  not  bolster,   support,  nor  deal with the  ad-
vantages  of  the  on-site  alternative  to  the  reader  and  our
community.

     Thank you again for the opportunity  to  make these comments.
                                    Respectfull
    RBS/jl
    cc: John  R.  Spencer,  Regional Administrator
        Environmental  Protection Agency,  Region 10
        1200  Sixth  Avenue
        Seattle, WA  98101

        Jones &  Stokes Associates, Inc.
        2321  P Street
        Sacramento, CA  95816
                                     19

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Response to Comments by R. Brock Shamberg, P. C., Attorney^
at Law

1.  The DEIS does not attempt to play down the use of on-
    site systems.  Chapter 5 explores this issue in depth.

    The DEIS is intended as an evaluation of impacts of the
    proposed sewerage decisions, rather than as a feasibility
    study.  The Facilities Plan "documents serve as feasibility
    studies.

2.  The DEIS discusses existing on-site system management
    on pages 137 and 138, and suggests additional mitigation
    measures on pages 150-152.  A document on the operation
    of septic systems is referenced on Page 151 of the DEIS.
    That document deals extensively with the management of
    on-site systems, dealing with both technical and institu-
    tional issues.

3.  The commentor states that adequate cost comparisons of the
    option of public sewers versus on-site sewers are lacking.
    This information was requested from the MOA by EPA but was
    never developed as part of the facilities planning process.
    A  20-year present-value analysis considering full life-cycle
    costs of both systems would be desirable.  The lack of this
    information has not constrained other analyses in the
    DEIS, and will not prevent funding decisions by EPA on
    other parts of the Facilities Plan.

4.  Comment acknowledged.  Expansion of the sewerage system
    is proposed to meet the requirements of an expanding com-
    munity and prevent pollution of the waters, not as a "make-
    work" project.

5.  The Facilities Plan and DEIS include numerous (about 70)
    sewer improvement projects to correct current and projected
    deficiencies, and to upgrade the interceptor system.  Nearly
    all of these facilities are described in the Facilities
    Plan in very general terms, such that detailed analysis
    in the DEIS was not possible.  The DEIS includes those
    facilities in a general way only, addressing the cumulative
    impacts of the overall plan, with detailed NEPA evaluations
    confined to the plant expansion, outfall. West Bypass Inter-
    ceptor,  and Southeast Interceptor projects only.

6.  The DEIS discusses surface-water hydrology and quality in
    the Hillside Area on pages 139, and 142-152.

7.  As  discussed in prior responses to comments, the DEIS
    evaluates  sewerage decisions proposed pursuant to the
    Clean  Water Act.   Water supply issues are discussed only
    as  they  interact with sewerage decisions.   See also the
    responses  to comments by HALO and Kathryn Reed.
                              20

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8.   The DEIS has identified possible deficiencies in current
    on-site system construction, operation, and maintenance,
    with the objective of providing information to the agencies
    and public that may allow reduction of potential public
    health threats.  It is the purpose of the report to evaluate,
    rather than bolster, the alternatives in the Facilities
    Plan.
                               21

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                RABBIT CREEK  COMMUNITY  COUNCIL
                        SRA BOX  261-M
                   Al-JCHORAGE, ALASKA   99507
 March  6,  1983
 Mr.  Clark Smith
 Environmental  Evaluation  Branch
 Environmental  Protection  Agency,  Region  10
 1200 Sixth Avenue,  M/S  443
 Seattle,  WA  98101

               Re:   EIS  Anchorage  Wastewater  Facilities;
                    Draft, November  1982

 Dear Mr.  Smith:

 The EIS Anchorage Wastewater  Facilities  Draft has  been reviewed
 with great interest by  the  officers,  directors and various members
 of the Rabbit Creek Community Council.   Many of the areas dis-
 cussed in this draft are  located  within  the  boundaries of our
 council.

 The following subjects, in  our opinion,  require further consid-
 eration and study:

      1)   The EIS does recognize the possible mix of septic
 systems and sewers.   Mitigating measures to  an adopted plan
 are not in question,  but  we urge  that the EIS stress the
 positive  benefits of continuing septic systems. The key to
 their success  will  be vigorous, enforced maintenance of the
 systems.   This natural  solution to  wastewater treatment is,
 we  believe,  untimately  safer  and  less costly than  sewers.

          Given the  continuance of large  lots (one  acre plus) ,
 the  cost  of  sewering the  entire Hillside area is simply too
 great to  be  borne by the  homeowner.   Alternatively, while
 sewers  and high density development throughout the Hillside
 area  would reduce the cost  of sewers  per homeowner lot,  the
 entire population of  Anchorage would  then be asked to share
 in the cost  of  construction and maintenance  of the system,
 an economic  burden which we feel  would prove equally unaccept-
 able.  Further,  it would  destroy  the  rural lifestyles in the
Hillside  area whose  continuance the Hillside Wastewater
Management Plan  was  directed  to emphasize.
                                                             9 1233
                                 22
                                                             •''-_ EVAtUATiON

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                                           March 6, 1983
                                           Page 2
     2)  Growth in the Anchorage area will be limited by
availability of water and effects of surface drainage before
it will be limited by the availability of sewers.

         a)  The draft EIS devotes little space to water
availability.  We would like to see mitigating measures dealt
with more specifically.  What sources of surface water must be
considered?  What is the long-range outlook for public ground-
water supplies?

         b)  Surface drainage is recognized in the EIS as a
problem.  There is little information about drainage in this
geologically young area, and drainage is continually disrupted
by road and home construction.  The EIS should stress that an in
depth sutdy of the impacts of development needs to be made — that
it is desirable to map flood plains and plan for flood control.
It will be essential to identify gaining and losing reaches of
streams so that septic wastes can be directed safely.  None of
this can be done without extensive detailed work.  The EIS might
specify approaches to these problems.

We look forward to the final Environmental Impact Statement that
incorporates the input made by this council and others.
                                   Lloyd V. Morris
                                   Vice President
                                   Rabbit Creek Community Council
LVM/ j It
cc:  John R. Spencer, Regional Administrator
     Environmental Protection Agency, Region 10
     1200 Sixth Avenue
     Seattle, WA  98101

     Jones & Stokes Associates, Inc.
     2321 P Street
     Sacramento, CA  95816

     Senator Ted Stevens, U. S. Senate
     Senator Frank Murkowski, U. S. Senate
     Representative Don Young, U. S. House of Representatives
                                 23

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Responses to Comments by Rabbit Creek Community Council

1.  The objective of an EIS is to evaluate the implications of
    an action, not to stress benefits that may be offset by
    potential adverse effects on public health.  The purpose
    of any sewerage system is to dispose of liquid waste in
    an environmentally-acceptable manner without risk to human
    health.  The analyses in the DEIS seriously question whether
    the on-site system alternative, as adopted in the Hillside
    Wastewater Management Plan, is capable of achieving this
    purpose.  EPA agrees that the success of this alternative
    depends, at least in part, on vigorously enforced maintenance
    of systems.

2.  Full life cycle cost data for sewers and on-site systems
    have never been provided to EPA to demonstrate cost-effective-
    ness of either system.

3.  The Facilities Plan and EIS assume that water availability
    will not be a constraint to growth in the 20-year period
    analyzed by the EIS.  The MOA is'drilling additional wells
    to meet short-term demand and is pursuing implementation
    of water importation from the Eklutna project for a long-
    term solution.  Groundwater will most likely continue
    to be used, subject to the management of the local groundwater
    basin to prevent salt intrusion from Cook Inlet.

4.  The MOA has established a requirement for specific drainage
    plans  (DEIS, page 146, 4th paragraph).  Areawide drainage
    planning and floodplain delineation are suggested in the
    EIS as additional mitigations.  The approach to areawide
    drainage planning should be consistent with other area
    plans underway or completed in the Anchorage Bowl.  These
    plans have been developed by contractors to the MOA, and
    data on the scope of services are available from the Planning
    Department.

    Floodplain delineations are normally prepared consistent
    with Corps of Engineers or Federal Emergency Management
    Agency criteria.
                               24

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IN REPLY REFER TO:


         UAES
United States Department of the Interior

            FISH AND WILDLIFE SERVICE
                 1011 E. TUDOR RD.
             ANCHORAGE. ALASKA 99503
                    (907) 276-3800
                                                             2 I MAR  !98j
         Mr. Clark Smith
         Environmental Evaluation Branch
         Environmental Protection Agency - Region 10
         1200 Sth Avenue (Fi/S 443)
         Seattle, UA  98101
                                          Re:   Draft EIS  City of  Anchoraya-, Alaska
                                               Waste Uater  Facilities - Uov. 1C82
         Dear fir. Smith:
         The U.S. Fish and Wildlife Service (USFU'S)  has  reviewed  the  document and
         offers the following comments:

         1.  The document would greatly benefit from more  in  depth  discussion of
             what is already known about the unconfined  and shallow aquifers of
             the Anchorage Bowl and their relationships  to surficial  and  shallow
             subsurface (upper 100-200 ft) soils and sedimentary  strata.

             Wet lands, Logs and streams  will be variously  traversed by pipes, and
             an evaluation of the potential problems that  will  require
             pre-construction design considerations  to protect  and  maintain the
             integrity of surface and subsurface aquifer should be  discussed  in
             detail in the EIS.

             For example, the alternative of tunneling for emplacement of a 78
             inch gravity line could present significant construction and
             post-construction problems  if the integrity of the geological
             formation "sealing" the shallow aquifers or the  stream channels  of
             creek crossings is and remains breached, causing water to seep  and
             flow along a least resistance path along the  tunnel  bore.  In
             addition, we are quite concerned over the possibility  of subsidence
             following tunnel construction.  This concern  is  particularly acute  in
             the area around Campbell and Little Campbell  Creeks.  Uo believe a
             more thorough discussion of this problem is warranted.

             Small cave-in's have already occurred in the  Anchorage area as  a
             result of breaks and have resulted in uncontrolled flow  along buried
             pipes.  Creaking the seal of perched aquifers during trenching  can
             also induce changes in wetland environment, including  those
             designated for preservation.
                                               25

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2.  The long term potential environmental  impact of "dewaterimj"  of the Rabbit
    Creek - Potter Creek Hillside  area  upon  the  water  requirements of Potter
    Refuge/Potter Harsh, through a combination  of ground-surface  water
    withdrawal and transportation  of  the withdrawn water as "sewerage"1 for
    treatment and disciiaryc outside the hillside drainage area,  should Lc
    discussed.  Potter Harsh,  located in the southeastern corner  of tine Potter
    Point Gar.ie kefujs, established in 1970  by the State legislature, supports
    diverse fish ana wilolne  resources or  high  public interest  throughout the
    year and requires high ar.iounts of surface and groundwatei1 inflow to
    Maintain the ecological quality of .tne  marsh - wetland environment.  The
    long ten.i effects of sewering  the hillsiue  area contiguous to Potter- Harsh
    should be discussed in terr.is of the overall  lony terr.i water  supply-demancs
    for the hillside area.

3.  llucii encroachment by transportation systei.is  crossing the marsn have
    sigr.if icantly reduced and  degraded  the  remaining land-water  quality,
    essential to the well being of tite  botanical,  resident and moratory biota
    of the r.iarsh.  Ue would regard, but not  necessarily endorse  until detailed
    plans  can be reviewed and  approved, alternative 1  and alternative 0 (Fig.
    3-fJ. ri. f,7) as preferred options  for sewer inc:  the  area.  Alternative 1
    should not, however, include emplacement of  the sewer line within the
    refuge boundary, dafinc-d as extending  seav/ard  from the "toe  of the
    bluff."  Alternative 3, by placing  the  inner sewer line- landward of the
    "toe of the bluff" and seav/ard of the  outer  right-of-way of  the railroad
    should have minimal impacts upon  the Potter  Harsh  habitat.

Be  advised that on Ilarch 19, 1983, a  meeting was held  in Anchorage and chaired
by  tiie Audubon Society to discuss  Potter Marsh.   The meeting v/as  well attended
and many pertinent factors influencing  Potter Harsh were discussed.  It was
agreed that within two weeks the Auciubon Society would provide a  summary of
the meeting.  Furthermore, liayor Tony Know 1 us of Anchorage agreed to convene
within thirty days,
                      task force  co-chaired  by  the  Municipality and the Alaska
developr.n		
uncertain what the results of tin's mayoral  task  force  will  be, we"art
convinced that those concerned with Potter  Harsh are  somewhat disturbed by the
piecemeal approach of existing and proposed  development.   For this reason we
urge you to consider carefully and utilize  the task force  prior to making
final decisions on pipe alignment, as  it relates to the Potter Harsh area.

We sincerely appreciate the opportunity to  ccmmont on  this  document.

                                       Sincerely,
                                               l  Director
                                      26

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Responses to Comments by U. S. Fish and Wildlife Service

1.  An in-depth evaluation of the aquifers in the Anchorage Bowl
    is beyond the scope of this EIS.  Much information on these
    aquifers is contained in the numerous publications of the
    USGS.

    The question of hydrologic impacts of sewer construction is
    addressed in some depth in Chapter 4 of the DEIS.  The dis-
    cussions contained in that section should provide sufficient
    guidance to design engineers in considering potential impacts
    and designing appropriate mitigations to protect the integrity
    of the aquifers.  The 70 proposed sewer construction projects
    could affect the shallow aquifer, as discussed in the
    DEIS; no impact on the artesian aquifer is expected.

2.  The tunneling proposed for the 78-inch interceptor is
    expected to occur within a clay lens, reported as over
    100 feet in thickness.  Preliminary soil borings indicate
    that this is a largely water-tight formation.  No measurable
    hydrologic impacts are expected if tunneling is confined
    to the clay layer.  Lateral movement of groundwater along
    the tunnel bore and subsidence above the tunnel are not
    likely.  The pipe will be placed in the tunnel and the
    space between the pipe wall and the tunnel bore will be
    sealed, inhibiting settlement and movement of water.

    The potential for such impacts will be further addressed
    in a separate Environmental Information Document being
    prepared by the MOA in support of a Finding of No Significant
    Impact (FONSI) covering the West Bypass Interceptor.

3.  These impacts are addressed on pages 142 and 143 of the
    DEIS.

4.  Comment acknowledged.

5.  Comment acknowledged.
                                27

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                          Chapter 3


               CHANGES AND CORRECTIONS TO DEIS
     This chapter presents changes and corrections to the
DEIS as a result of public review, comments, and reviews by
the preparers.  Portions of relevant pages of the DEIS are
reproduced, with changes typed in italics in context on the
page.
                                 29

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                    Revisions  to  Page  viii
     A  primary characteristic of a wetland  is,  obviously,
 the presence of water.  The presence, characteristics,  and
 movement of this water are termed hydrology.  Hydrologic
 values  of wetlands  include retention of rainfall  and  snowmelt
 runoff, augmentation of stream base flow, water quality benefits,
 and groundwater recharge.  Loss of wetlands could result
 in elevated flood and erosion risks, and alteration of  stream
 flow and water quality.

     Planned growth, supported in part by sewerage expansion,
 together with  the construction of facilities within and adjacent
 to  the  wetlands, may result in the  loss of  more than  half of
 all nontidal wetlands in  the Anchorage Bowl.

     Construction of sewers within wetlands as  proposed in
 the facilities plan (about 26 sewer facilities  in many  of
 the area wetlands)  will result in destruction of  vegetation
 and loss of wildlife habitat along pipe alignments.   Heavy
 equipment crushes or removes vegetation and compacts  peat
 deposits.  Areas of bog wetlands stripped of vegetation
 generally do not revert to the original habitat type, but
 instead are overgrown by  ruderal vegetation or  are kept barren
 by foot or off-road vehicle traffic.  Long-term alteration
 of habitat is apparent in aerial photographs taken long after
 emplacement of pipe.  In  Campbell-Klatt Bog, for  example,
 one sewer line is proposed to pass through an area used by
 Canada  geese and other waterfowl as a nesting area.

     Much more subtle, but perhaps more significant,  is the
 delayed impact on hydrologic features of wetlands.  Most
 peat bogs, such as 'those  comprising the majority  of wetlands
 in the  study area,  are natural water-retaining  basins.  In
 some ways, their character is analogous to a teacup filled
 with water and cotton.   If a buried pipe were placed  through
 a wetland, and if backfill material were used which did not
 impede water movement,  the action would be approximately
 analogous to chipping the rim of the cup, allowing some of
 the water to drain  away.   To continue the analogy, water
 level  in the cup (bog)  will probably sink below the level
of the damaged area because the cotton (peat) will act  as
a wick bringing moisture to the outlet area.  This dewatering
process will adversely change the biological and  hydrologic
values  of wetlands.
                              30

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                    Revisions to Page 34
     The combined facilities plan describes an areawide sewerage
facilities expansion program serving the Anchorage Bowl and
extending over a 20-year period.  It encompasses:

     o Alternatives for expansion of Point Woronzof WWTP;

     o Extension of the existing outfall by 1,500 feet;

     o Study of adding a diffuser at the end of the extended
       outfall;

     o Alternatives for disposal of sludge solids from the
       treatment process;

     o Alternatives for construction of the West Bypass
       interceptor sewer;

     o Construction of the Southeast interceptor sewer, includ-
       ing sewerage alternatives in the Rabbit Creek-Potter
       Creek area;

     o Provisions for on-site sewerage of a portion of the
       Hillside area;

     o Construction of about 70 sewer improvement projects
       through 1998.

The facilities plan sets  forth  a MOA-recommended plan, suggest-
ing implementation  of  specific  alternatives.

     For EIS purposes the above project alternatives,  except
for  the  70 sewer -improvement projects, are evaluated  in  detail
in the EIS.  The 70 sewer improvement projects  are addressed
only with specific reference to wetland impacts  and in general
terms  relative to cumulative impacts.  They are  not covered
pursuant  to NEPA requirements  by this EIS  and  will not be  candi-
dates  for federal funding without future NEPA  review.  The
Recommended Plan, which consists of  the first  seven projects
 listed above,  is presented  and analyzed in greater depth,
with alternatives  analyzed  in  sufficient detail to provide
a full perspective  of the consequences of  alternative actions.
                                31

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                     Revisions  to  Page  36
                      Recommended Plan

      The Wastewater Facilities  Plan  for  Anchorage,  Alaska (MOA
 June  1982)  and  the Hillside Wastewater Management Plan (MOA
 May  1982)  together set  forth  an area-wide  Recommended Plan for
 wastewater collection,  treatment and disposal  in the  Anchorage
 Bowl.   The Hillside plan, which designates areas for  sewerage,
 on-site sewage  disposal systems, and no  sewerage service
 (generally unsuitable for on-site systems),  was  adopted by
 the  Municipal Assembly  on May 18, 1982.  This  is considered
 a  Recommended Plan in the context of EIS analyses.   The
 Wastewater Facilities Plan for  Anchorage,  Alaska acknowledged
 the  adopted Hillside plan and includes sewerage  service to the
 areas so designated in  that plan.  The wastewater facilities
 plan  also  evaluates alternatives in  the  remainder of  the
 Anchorage  Bowl  and presents a Recommended  Plan selected from
 those alternatives.

      The Recommended Plan for providing  wastewater  collect-Ion,
 treatment  and disposal  -Is described  in this  section.   The
 expansion  of the  Point  Woronzof treatment  plant  is  described
 first3  followed by the  outfall  and diffuser, major  interceptor
 sewers,  and Hillside sewerage plans.  The  remaining 70 sewer
 improvement projects, which are not  described  in detail and
 are  not covered in detail in  the facilities  plan or this EIS,
 are  mentioned last.  These projects  are  listed for  information
 only,  to provide  the full context of the Facilities Plan.

      The Point  Woronzof WWTP  would be expanded from its current
 effective  capacity of 22 MGD  annually to 58  MGD  (average annual
 flow).   (Current  design capacity is  34 MGD,  although  the plant
 cannot  meet discharge requirements at a  design flow rate over
 22 MGD.)   This  expansion would  be achieved through construction
 of three additional primary clarifiers,  modification  of other
 portions of the liquid  processing to increase  capacity (Figure 3-1),
 addition of another sludge incinerator to  the  solids  process
 (Figure 3-2), and consideration of alternative disposal methods for
 incinerator ash.  These  improvements are described  below in the
 order of the treatment  process.
                       Cost Summary

     Federal regulations require that a comprehensive cost
analysis of all wastewater treatment plans be undertaken.
The most cost-effective plan is defined as the lowest present-

                               32

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worth alternative that meets water quality standards in the
absence of overriding non-monetary costs.  Present-worth
evaluation is the method most commonly applied to evaluate
the cost of alternative facilities.  Present-worth evaluations
include:

     o Probable construction costs:  engineering, legal and
       administrative fees, contingencies and interest.

     o Operation and maintenance:  labor, materials, supplies,
       spare parts, chemicals and power, usually on an annual
       basis.

     o Remaining value of improvements:  Value of facilities
       at the end of the planning period.

     Table 3-3 shows the criteria used to determine the costs
of the above present-worth components.   Tables 3-4 through 3-10
show present-worth alternatives described in this chapter.

     Present-worth costs for the outfall extension and diffuser
are not included in the tables.  A 1,500-foot outfall extension
is estimated to cost $5,660/000, and a 1,000-foot diffuser
is estimated to cost $3,770,000  (MOA 1982).

      A  summary  table  of present worth  costs  (Table  3-12)  is
 attached  showing  comparable  cost data  for  the Recommended
 Plan  facilities,  to  the extent  comparable  data are  available.

User Costs

     Costs to individual MOA sewer customers  would  increase
as a result of expansion of the wastewater facilities
 (Table 3-11).  Those customers  served by sewers would  sustain
a rate increase estimated at from 22 percent  to 34  percent
in 1985, and 30 percent to 40 percent in 1999 as a  result
of the Recommended Plan, depending on funding sources  for
construction.

     The low range in these estimates assumes  that  U.  S.  EPA
would provide 75 percent construction funding for the  Point
Woronzof WWTP improvements, and  the State would provide
an additional 12.5 percent; that the State would fund  50  percent
of all other expansion; and that local  funds  would  comprise
the balance.  The high range assumes no  U. S.  EPA funding,
but rather that all construction cost  funding would be
50 percent State and 50 percent  local.   In both cases, all
repair and rehabilitation work,  as well  as maintenance and
operating costs, would be paid  with 100  percent local  funds.
                               33

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        Table 3-12.  Summary of Present Worth Costs -
                      Recommended Plan
Item                                              Present Worth


Point Woronzof Wastewater Treatment
 Plant expansion                                  $5,431,000

Incinerator ash disposal alternatives:

  - landfill                                       1,198,900

  - outfall                                          574,900

  - lagoon                                           983,700

Outfall, diffuser                                       (1)

West Bypass Interceptor sewer                           (2)

Southeast Interceptor                                   (3)

Rabbit Creek Interceptor, pump station             3,975,000


(1)  Not available.

(2)  Being revised by MOA;  original estimates ranged from
     $8,953,000 for pump station and force main to $13,609,000
     for open trench construction.

(3)  Not provided in facilities plan.


SOURCE:   Anchorage Wastewater Facilities Plan June 1982.
                               34

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                    Revisions to Page 153


                          Chapter 6


                  CULTURAL RESOURCE IMPACTS


                   Archeological Resources

     The Anchorage Bowl area is not noted for extensive use
by prehistoric populations.  A known archeological site occurs
at Point Woronzof one-half mile south of the WWTP (49-TYO-030).
The Tanaina were known to have fish camps at the mouth of Ship
Creek during early historic times.  A more detailed description
of archeological resources is available to qualified persons
by request from EPA Region 20, at the address on the cover
of this EIS.

     Impacts to known or newly-discovered archeological sites
can be minimized through avoidance where possible.  The faci-
lities plan does not threaten the site in the Point Woronzof
area.  A preconstruction survey of the expansion area at the
WWTP should be conducted as a precautionary measure.  Since
watercourses are often places of high habitation probability,
a brief reconnaissance at all stream crossings is recommended.
During all construction activity, a localized work halt should
occur and the State Historic Preservation Officer should be
immediately notified if an archeological site is uncovered.


                       Historic Places

     Although Anchorage is a comparatively young city, having
been established in 1915, it has a number of places of historic
value, including seven sites listed in the National Register
of Historic Places;

     o  the Oscar Anderson House on 4th Avenue
     o  the Old Federal Building and U.S. Courthouse at 601
         W. 4th Avenue
     o  the Campus Center .on Wesley Drive
     o  the Eklutna Power Plant northeast of Anchorage
     o  the Old St. Nicholas Russian Orthodox Church on
         Eklutna Village Road
     o  the old Anchorage City Hall at 524 W. 4th Avenue
     o  the Pioneer School House at 3rd Avenue and  Eagle St.
None
     of  these  sites is affected by the facilities plan.
                               35

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             Explanation of Figure 8-5, page 181
     Figure 8-5 on page 181 (repeated as Figure B-8 on page
B-25,  Appendix B) bears a vertio-al axis designated by "W/V
and P/V,  g/d-m3."  The reader should be referred to pages B-19
and B-24  of Appendix B for a further explanation.  W stands
for waste biochemical oxygen demand (WBOD)3 P stands for phyto-
plankton  dissolved oxygen deficit (PDOD), V is the volume of
the receiving water.  These factors are expressed.as grams
per day per cubic.meter of the receiving water (g/d-m ).

     The  chart illustrates that BOD loading and oxygen deple-
tion due  to the Point Woronzof outfall are not a problem in the
Knik Arm.
                               36

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    100
     10
                      wd od
eo
        v  \Boston
         \P\HarboY
                   \
 •o
 X
 O)
N
o.

•a
c
(9
                     \
     .1
                               Houston Ship
                               Channel
                        QDelaware  River
                              v
   ocean   \
  outfall      \
                                \
A
    -oi
           Knik Arm
                                     \
                           \
                     w
                                    \
                                      i
                                      lmg/L wdod
                                        lOmg/l pdod
                                        \
                                        m9/l  pdod
                                        \
   .001
                present  discharge

                proposed discharge
                   10
                               10'
                                    10
                 FLUSHING  TIME  IN  DAYS
        Figure  8-5.  Estuarine Waste  Assimilation Diagram.
                              37

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                    Revisions to Page 213
EIS Wetlands Workshop - October 16, 1981

     An EIS workshop emphasizing wetlands work was held in
the new Federal Building in Anchorage on October 16, 1981.
A major purpose was to identify a detailed scope of expanded
biological  studies to satisfy both EIS needs  and MOA special
study needs.  Federal, state and local agency representatives
attending the workshop received handouts outlining a tentative
study scope and modifications were suggested by participants.
 (The expanded biological studies were not funded for this
EIS.)


Facilities  Plan Public Meeting - January 20,  1982

     A 201  Facilities Plan public meeting was held on
January 20, 1982 at West High School, attended by about
25 people.  Wastewater project alternatives were presented
and EIS issues discussed.  Primary public attention was
focused on  Hillside and Potter Marsh impacts that might
occur from  sewering of the south Hillside.


EIS Wetlands and Hillside Workshop - April 14, 1982

     A two-session EIS workshop was held in Anchorage  on
April 14, 1982 to discuss wetlands and Hillside area issues.
The first session, attended by about 15 people, was held
in the Hill Building.  The second session, attended by about
10 people, was held at Wendler Junior High School.  Issues
discussed at the workshops included the outfall, Hillside
issues and  specific wetland impacts.


           Comments Received Through Distribution
                of the Preliminary Draft EIS

     The Preliminary Draft EIS was circulated for comments
on August 30,  1982 to certain public agencies and groups
that were active participants in EIS scoping.  Comments
were received at a meeting in the MOA Telephone Utility
offices  on September 15,  1982.  Those comments have been
considered in completing this Draft EIS.
                               38

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                           Chapter  4


            DISTRIBUTION LIST, NOTIFICATION LIST


     The following pages contain' listings of the agencies and
individuals who were provided copies of the DEIS.  Additional
copies were also distributed through the Municipality and
through Ott Water Engineers.

     Notices of availability of the DEIS were sent to an addi-
tional group of agencies and individuals.  These are shown
on the "DEIS Notification List."
                               39

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                          DEIS DISTRIBUTION LIST
Alaska Department of Environ-
 mental Conservation
Pouch 0
Juneau, Alaska  99811

U. S. Public Health Service
Indian Health Service
3rd  & Gamble Streets
Anchorage, Alaska  99501

Alaska Department of Community
  & Regional Affairs
Pouch B
Juneau, Alaska  99811

Office of Legislation, A-102
Environmental Protection
  Agency
Room 3105, Waterside Mall
Washington, DC  20460

Oil  & Special Materials
  Division (WH-448)
Water Programs  Operations
Environmental Protection
  Agency
Room 2106, Waterside Mall
Washington, DC  20460

Office of the Governor
State of  Alaska
Division  of Development and
  Planning
Pouch AD
State Capitol
Juneau, Alaska  99811

State Clearinghouse,
A-95 Coordinator
Office of the Governor
State of  Alaska
Pouch AD
Juneau, Alaska  99801

Alaska Department of Fish
  and Game
333 Raspberry Road
Anchorage, Alaska  99502
Department of Natural Resources
323 E. 4th Avenue
Anchorage, Alaska  99501

Alaska Energy Allocation Assistance
 Office
338 Denali Street
Anchorage, Alaska  99501

Alaska Department of Commerce & Economic
 Development
Pouch D
Juneau, Alaska  99811

Office of Public Affairs, A-107
Environmental Protection Agency
Room 3014, Waterside Mall
Washington, DC  20460

Commissioner
Department of Fish and Game
Subport Building
Juneau, Alaska  99801

Facility Requirements Division, WH-595
Environmental Protection Agency
401 M Street, SW
Washington, DC  20460

Alaska Department of Highways
802 3rd Street - Douglas
Juneau, Alaska  99513

Mr. Paul Larson
ATTN:  AF2T-FE-EQ
HQ, 172nd INF BDE  (AK)
Fort Richardson, Alaska  99505

Jose Vicente, Centrum Engineering
524 International Airport Rd.
Anchorage, Alaska  99503

Mr. Rick Kentopp
Karolaska Community Association
Box 4-1875
Anchorage, AK  99509

Mr. Don Follows
SRA Box 1586
Anchorage, AK  99507
                                  40

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Mr. Erv Martin
SRA Box 9373
Eagle River, AK
99577
Dee Lane
4434 East 5th Avenue
Anchorage, AK 99504

Mr. Todd Miner
P. O. Box. 3657
Anchorage, AK  99510

Michelle Michaud
P. O. Box 4-1645
Anchorage, AK  99509

Ms. Kathryn Tubbs
1234 West Hillcrest Drive
Anchorage, AK  99503

Mr. Mark Premo
2905 West 35th Avenue
Anchorage, AK  99503

Mr. Nels Kjelstead
Crews, Maclnnes & Hoffman
3812 Spenard Road, Suite 100
Anchorage, AK  99503

Ms. Nelda Warkentin
SRA Box 2060-W
Anchorage, AK  99507

Mr. Jim Swing
4401 Woronzof Drive
Anchorage, AK

Mr. Richard Pittenger
6602 Lakeway Drive
Anchorage, AK  99502

Mr. Mike Szyrnanski
SRA Box 1304 B
Anchorage, AK  99502

Mr. Ron Alleva
3216 Thompson Avenue
Anchorage, AK   99504
Mr. Al Carlson
Department of Natural Resources
323 East 45th Avenue
Anchorage, AK  99501

Mr. Larry Hayden
Resource Development Council
Box 516
Anchorage, AK

Ms. Hope Reed
222 West 13th Avenue
Anchorage, AK  99501

Ms. Jane Gray, AK PIRG
P. 0. Box 1093
Anchorage, AK  99510

Mr. Bob Fleming
SRA Box 2921
Wasilla, AK  99687

Mr. Andy Achilles
P. 0. Box 10-2154
Anchorage, AK  99511

Mr. Wayne Westberg, Chairman
Alaska Water Resources Conmittee
SRA Box 1559
Anchorage, AK  99507

Ms. Sue Brownfield
Huffman/0'Malley Council
SRA 1563-C
Anchorage, AK  99507

Sand Lake Branch Library
7015 Jewel Lake Road
Anchorage, AK  99502

Spenard Community Library
2739 C Street
Anchorage, AK  99503

ZJ Loussac Library
524 West 6th Avenue
Anchorage, AK  99501
                                   41

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Sampson Dimond Branch Library
Dimond Mall
Anchorage, AK  99507

Mountain View Branch Library
120 South Bragaw
Anchorage, AK  99508

Grandview Gardens Branch Library
1325 Primrose
Anchorage, AK  99504

Alaska Resources Library
701 C Street
Anchorage, AK  99513
                                      42

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James B. Wright
Black & Veatch
1207 E. 45th Avenue, Suite 400
Denver, CO  80239

Paul Arneson
Nongame Coordinator
Department of Fish and Game
333 Raspberry Road
Anchorage, AK  99502

John Pitcher
2839 Telequana, Apt. 1
Anchorage, AK  99503

Clark Smith
0. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA  98101

Bruce Phelps
Anchorage Planning Department
Pouch 6-650
Anchorage, AK  99502

Reford Reid
Alaska Dept. of Environmental Conservation
437 E Street, Suite 201
Anchorage, AK  99501

Ken Lauzen
Anchorage Telephone Utility
600 E. 38th Avenue
Anchorage, AK  99503

Ted Rockwell
O. S. Army Corps of Engineers
Alaska District
P. O. Box 7002
Anchorage, AK  99510

Lance Trasky
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK  99502

Wayne Pichon
U. S. Fish and Wildlife Service
1011 E. Tudor Road
Anchorage, AK  99502

Ray Blackman
Manager, Engineering & Planning
Anchorage Water & Sewer Utilities
3000 Arctic Boulevard
Anchorage, AK  99503

Rikki Fowler
Alaska Dept. of Environmental Conservation
437 E Street, Suite 201
Anchorage, AK  99501

Ted Rockwell
U. S. Army Corps of Engineers
Alaska District
p  o. BOX  7002
Anchorage,  AK   99510
 Louis  J.  Bonito
 Anchorage Water  & Wastewater Utility
 3000 Arctic  Boulevard
 Anchorage, AK  99503

 James  Lieb
 Division  of  Game
 Department of Fish and Game
 Subport Building
"Juneau, AK   99801

 Roger  Harris
 318 Cardinal Court
 Mill Valley, CA  94944

 Jon R. Nickles
 U. S.  Fish and Wildlife Service
 7136 Terry Street
 Anchorage, AK  99502

 Eulalie Sullivan
 Office of Coastal Management
 Pouch  AP
 Juneau, AK   99811

 Judy Stanek
 Federation of Community Councils
 801 West  Firewood Lane
 Anchorage, AK  99503

 Sandra L. Christy
 Ott Water Engineers
 Building  D,  Suite 8
 4790 Business Park Boulevard
 Anchorage, AK  99503

 Robert Rasmussen
 Department of Health and
   Environmental Protection
 825 L  Street
 Anchorage, AK  99501

 Edward G. Burton
 Burr,  Pease  & Kurtz
 810 N  Street
 Anchorage, AK  99501

 Ron Kreizenbeck
 U. S.  Environmental Protection Agency
 Alaska Operations Office
 Pouch  0
 Juneau, AK   99811

 Ron Morris,  Chief
 National  Marine  Fisheries  Service
 701 C  Street
 Anchorage, AK  99513

 District  Engineer
 U. S.  Army Corps of Engineers
 Alaska District
 P. O.  Box 7002
 Anchorage, AK  99510

 Alaska Center  for  the  Environment
 1069 W.  Sixth  Avenue
 Anchorage, AK  99501
                                            43

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Weymouth  Long
U.  S.  Soil Conservation Service
2221 E. Northern  Lights Boulevard
Anchorage, AK   99504

Paul D. Arneson
Nongame Coordinator
Alaska Department of Fish and Game
333 Raspberry  Road
Anchorage, AK   99502

George Wolfson
c/o Hanover  Group
1100 Alma Street, Suite 200
Menlo  Park,  CA  94025

Bob Martin
Alaska Dept. of Environmental Conservation
437 E  Street,  Suite 201
Anchorage, AK   99501

Paula  P.  Easley
Resource  Development Council
Box 516
Anchorage, AK   99510

Leslie L. Brattain, P.E.
Tryck  Nyman  &  Hayes
740 I  Street
Anchorage, AK   99501

William Carlson
5346 W. 73rd
Anchorage, AK   99502

Bill Ryan
U.  S.  Public Health Service
Box 7-741
Anchorage, AK   99510

R.  David  Black
Ott Water Engineers
Suite  8,  Building D
4790 Business  Park Boulevard
Anchorage, AK   99503

Tom Arminski
Alaska Department  of Fish and Game
333 Raspberry  Road
Anchorage, AK   99502

Debra  Clausen
Alaska Department  of Fish and Game
570 W. 53rd Avenue
Anchorage, AK   99502

Dick Hutson
Anchorage Water and Wastewater Utility
3000 Arctic Boulevard
Anchorage, AK   99503

Butch West
Quadra Engineering
301 E. Fireweed Lane
Anchorage, AK   99503

Jeffrey Bowles
Central Alaska Utilities,  Inc.
1301 E. 80th Avenue
Anchorage, AK   99507
Carl Aragawa
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK  99502

Wendy Wolfe
Office of Coastal Management
Pouch AP
Juneau, AK  99811

Bill Donaldson
Marine Coastal Habitat Management
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK  99502

Bill Lawrence
U. S. Environmental Protection Agency
Alaska Operations Office.'
701 C Street, Box 19
Anchorage, AK  99513

Dan Crevensten
Municipality of Anchorage
Pouch 6-650
Anchorage, AK  99502

Eino A. Reinikka
1400 K Street
Anchorage, AK  99501

Al Carson
Department of Natural Resources
323 E. 4th Avenue
Anchorage, AK  99501

George F. Shaw
Retherford & Associates
Box 6410
Anchorage, AK  99502

Peg Tilestom
4780 Cambridge Way
Anchorage, AK  99503

Jean Elder
Environmental Evaluation
U. S. Army Corps of Engineers
Alaska District
P. O. Box 7002
Anchorage, AK  99510

Tim Brabets
U. S. Geological Survey
1209 Orca Street
Anchorage, AK  99501

Jim Sweeney
Anchorage Telephone Utility
600 E. 38th Avenue
Anchorage, AK  99503

Joel Grunewald
Anchorage Solid Waste Management
3500 E. Tudor Road
Anchorage, AK  99507

Ted Trueblood
Alaska Railroad
100 W. 1st Avenue
Anchorage, AK  99501
                                          44

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George Franklet
Alaska Dept. of Environmental Conservation
Pouch O
Juneau, AK  99811

Ed Bangs
Kenai National Wildlife Refuge
U. S. Pish and Wildlife Service
Soldotna, AK  99669

Anchorage Air Pollution Control Agency
825 L Street
Anchorage, AK  99501

Sharon 0. Richards
2306 Douglas Drive
Anchorage, AK  99503

Donald E. Wilson
Kinnetic Laboratories Incorporated
519 W. 8th Street
Anchorage, AK  99503

M. Scott Christy, Ph.D.
R. A. Kreig & Associates, Inc.
1503 W. 33rd Avenue
Anchorage, AK  99503

Sidney Clark
1506 W. 36th Avenue
Anchorage, AK  99503

Robert Kubick
Royal Krest Construction Company
621 W. Dimond Boulevard
Anchorage, AK  99502

Giles McDonald
HALO
P. O. Box 10-096
Anchorage, AK  99511

Richard Pittenger
6602 Lakeway Drive
Anchorage, AK  99502
Jose Vincente
4335 Laurel
Anchorage, AK
99507
Consuela Wassink
BLM Public Information Officer
P. 0. Box 1159
Anchorage, AK  99503
Franz Vail
AEE
810 W.  72nd Avenue
Anchorage, AK  99502

William J. Schaedel
Anchorage School District
4600 De Barr Road
Anchorage, AK  99504

Martha  Woodward
•Harding-Lawson Associates
624 W.  International Airport Road
Anchorage, AK  99502

Charles E. Hawkes
Regional Architect
Box 4-2540
University of Alaska
Anchorage, AK  99509

John E. Lobdell, Ph.D.
Environmental Archaeologist
SRA - Box 1026C
Anchorage, AK  99502

Marilyn Barker
2440 Lake George Street
Anchorage, AK  99504

Clifton Eames
National Wildlife Federation
835 D Street, Suite 204
Anchorage, AK  99501

Bill Lloyd
U. S. Army Corps of Engineers
P. 0. Box 7002
Anchorage, AK  99510

Wayne Pichon
4550 Edinburgh Drive
Anchorage, AK  99502

Dr. Lidia Selkregg
Box 2217
Anchorage, AK  99504

Harry Wassink
1340 W. 23rd Avenue,  Apt.  A
Anchorage, AK  99504
                                           45

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                               DEIS NOTIFICATION LIST
Andy Achilles
P. 0. Box 10-2154
Anchorage, AK  99511

Ron Alleva
3216 Thompson Avenue
Anchorage, AK  99504

Paul B. Baer
3622 Wesleyan Drive
Anchorage, AK  99504
Jo Blackman
3958 Reka
Anchorage, AK
99504
Tim Buckley
SRA Box  4005-B
Anchorage, AK  99502

Kenneth  Cannon
CCC Architects
431 W. 7th Avenue, Suite 100
Anchorage, AK  99501

Don Follows
RSA Box  1586
Anchorage, AK  99507

Bill Gee
3201 W.  48th Avenue
Anchorage, AK  99503

Jane Gray
AK PIRG
P. 0. Box 1093
Anchorage, AK  99501

Debby Johnston
914 W. 23rd Avenue, Apt. D
Anchorage, AK  99503

Joe P. Josephson
425 G Street, Suite 930
Anchorage, AK  99501
Rick Kentopp
Box 4-1875
Anchorage, AK
99509
John Klinger
5828 Winding Way
Anchorage, AK  99504

Paul Larson
ATTN:  AF2T-FE-EQ
HQ, 172d INF BDE  (AK)
Ft. Richardson, AK  99505

Ben Marsh
2926 Drake Drive
Anchorage, AK  99504

Christina Matallanna
917 E. 20th Avenue
Anchorage, AK  99501
Larry Albert
P. O. Box 3-3934 ECB
Anchorage, AK  99501

Jane Angvik
1538 Orca Street
Anchorage, AK  99501

Robert Baldwin
"4907 Roger Road
Anchorage, AK  99507

Sue Brownfield
SRA 1563-C
Anchorage, AK  99507

Helen .Butcher
P. 0. Box 4-1203
Anchorage, AK  99509

Fred Chiei
P. 0. Box 148
Anchorage, AK  99501.

Bob Fleming
SRA Box 2921
Wasilla, AK  99687

Per Fossum
ASTS
420 L Street
Anchorage, AK  99501

Mike Holloway
Rainbow viy.
Indian, AK  99540

Dale Johannes
7731 Anne Circle
Anchorage, AK  99504

Toni Jones
310 K Street, Suite 407
Anchorage, AK  99501

Nels Kjelstead
Crews, Maclnnes & Hoffman
3812 Spenard Road, Suite 100
Anchorage, AK  99503

Dee Lane
4434 E. 5th Avenue
Anchorage, AK  99504

Mr. T. Lovebit
SRA Box 373-K
Anchorage, AK  99507

Greg Magee
816 N. Hoyt, A
Anchorage, AK  99504
                             Carol Maser
                             2526 Glenwood
                             Anchorage, AK
               99504
                                          46

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Roger McShea
308 G Street, Suite 201
Anchorage, AK  99501

Michelle Michaud
P. O. Box 4-1645
Anchorage, AK  99509

Todd Miner
P. O. Box 3687
Anchorage, AK  99510

Rick Mystrom
2727 Iliamna Street
Anchorage, AK  99503

Roberta Piper
201 E. 16th Avenue, Apt.
Anchorage, AK  99501
          312
Mark Premo
2905 W. 35th
Anchorage, AK
99503
Don Smith
3002 Spenard Road, #403
Anchorage, AK  99503

Kim Sundberg
SRA Box 1720-E
Anchorage, AK  99507

Kathryn Tubbs
1234 W. Hillerest Drive
Anchorage, AK  99503

Nelda Warkentin
SR Box 2060-W
Anchorage, AK  99507
William F. Meehan, Jr.
2941 Madison Way
Anchorage, AK  99504

Bill Miernyk
3910 Laun Lane
Anchorage, AK  99504

Ruth Moe
SRA Box 1547-R
Anchorage, AK  99507

Raymond Pearce
7944 Highlander Drive
Anchorage, AK  99502

James M. Powell
2143 Churchill Drive
Anchorage, AK  99503

Hope Reed
222 W. 13th Avenue
Anchorage, AK  99501

Cheryl L. Stewart
1247 Richardson Vista,
Anchorage, AK  99501

Mike Szymanski
SRA Box 1304-B
Anchorage, AK  99502

Dave Walsh
3104 Brookside
Anchorage, AK  99503
                                                     #81
                                              47

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                         REFERENCES


Gosselink, J. G.,  E. P. Odum, and R. M. Pope.  1973.  The
     value of the  tidal marsh.  Center for Wetland Resources,
     Louisiana State University, Baton Rouge.  30 pp.

Nixon, S. W.  1980.  Between coastal marshes and coastal waters -
     a review of twenty years of speculation and research
     on the role of salt marshes in estuarine productivity
     and water chemistry.  In:  P.  Hamilton and K. B. MacDonald
      (eds.).  Estuarine and Wetland Processes.   Plenum Publ.
     Co., New York.  Pp. 437-525.

Sanville, W.  1981.  Productivity response of an Alaskan wetland
     plant community to nutrient enrichment, Draft report.
     EPA Corvallis Environmental Research Laboratory, Corvallis.
     22 pp.

Schwartz, L. N.   1982.   The effects of sewage on a Lake Champlain
     wetland, Vermont.   Bull. Ecol. Soc.  Am. 63:155.
                               48

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