fcPA 910/9-83-099

       United States
       Environmental Protection
       Agency
       Water
Region 10
1200 Sixth Avenue
Seattle, WA 98101
EPA/10 SEATTLE'
&EPA  Environmental
        Impact
        Statement
April 1983
            Draft
        Municipality of Metropolitan Seattle
        Sludge Management Plan

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   574
REPLY TO
ATTN OF:
U.S.   ENVIRONMENTAL  PROTECTION  AGENCY

                      REGION  X

                  1200 SIXTH  AVENUE

             SEATTLE, WASHINGTON  98101
          M/S 443
      TO:  All Interested Government Agencies, Public Groups and Citizens

      Enclosed for your review and comment is the Draft Environmental Impact
      Statement (EIS) on the proposed Municipality of Metropolitan Seattle
      (Metro) Sludge Management Plan.  The Environmental Protection Agency
      (EPA) has given Metro a grant for the planning phase of this project
      under Section 201 of the Clean Water Act.  EPA has prepared this Draft
      EIS on its proposed approval of Metro's Plan pursuant to Section
      102(2)(c) of the National Environmental Policy Act (NEPA) of 1969 and
      implementing Federal regulations.

      In addition, in order to avoid duplication of effort and unnecessary
      expense, this Draft EIS is also intended to meet the requirements of the
      State of Washington Environmental Policy Act (RCW 43.21C).

      EPA will announce the availability of this document in the Federal.
      Register, on Friday, April 15, 1983, which will begin a 45-day review
      period.  If you have any comments on the Draft EIS or wish to provide
      additional information for inclusion in the Final EIS, we would
      appreciate hearing from you before the close of the comment period on
      May 31, 1983.  All comments received will be used by Environmental
      Protection Agency in evaluating the effects of approving the Plan.
      Please send your comments to:
                                   Kathryn Davidson
                                   Environmental Evaluation Branch
                                   Environmental Protection Agency
                                   1200 Sixth Avenue
                                   Seattle, Washington  98101
                                                                    M/S 443
      Public hearings on the Draft EIS and Metro's Draft Plan will
      Seattle at the Federal Building, 915 Second Avenue, on May 17,
      at the Arlington Middle School in Arlington, Washington, on
      May 19, 1983.  Both hearings will begin at 7:30 p.m.
      meetings will be held in Seattle on May 3, 1983 and
      May 5, 1983 at the same locations and times.
                                                                   be held in
                                                                     1983 and
                                                            Public information
                                                          in Arlington on

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               DRAFT
   ENVIRONMENTAL  IMPACT STATEMENT
MUNICIPALITY  OF  METROPOLITAN SEATTLE
       SLUDGE MANAGEMENT PLAN
            Prepared  by:

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

   Jones &  Stokes Associates, Inc.
           2321 P Street
        Sacramento, CA  95816
             April  1983
                              Responsible Official;
UJ1M.
                                              A
                                      jpencer
                                       Administrator
                                April 1, 1983
                              Date

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                      TABLE OF CONTENTS
EXECUTIVE SUMMARY                                         1
     Purpose and Need for Action                          1
     Role of Environmental Impact Statement               2
     Description of Alternatives                          2
          Background                                      2
          Long-Range Management Alternatives              3
          Near-Term Plan                                  4
          Subsequent Metro Planning                       4
     Assessment of Impacts                                5
          Impacts of No Action                            5
     Public Involvement                                  12

CHAPTER 1 - INTRODUCTION                                 13
     Environmental Impact Statement Requirement          13
     Organization of the EIS                             13
     Metro's Sludge Management Plan                      14
          Purpose and Need                               14
          Development of .the Sludge Management Plan      14
     EIS Context                                         15
          Major Issues Addressed by EIS                  15
     Public Participation                                17
     Legal, Policy, and Institutional Considerations     17
          Federal Requirements Relevant to Sludge
            Management and Disposal                      18
          Federal Requirements Relevant to EIS           21
          State Requirements                             24
          Local, Requirements                             26

CHAPTER 2 - DESCRIPTION OF SLUDGE MANAGEMENT
  ALTERNATIVES                                           27
     Overview of Sludge Management Concepts              27
          Sludge Management Principles                   27
          Sludge Management Approaches of United
            States Cities                                28
          Sludge Management in Washington Cities
            Outside Metro Boundaries                     30
     Metro's Existing Sludge Management Methods          31
          Introduction                                   31
          Sludge Treatment                               31
          Present Sludge Transport and Reuse Methods     34
          Past Sludge Disposal and Reuse Methods         37
          Pretreatment and Source Control                37
     Existing Metro Sludge Characteristics               39
          Sludge Quantities                              39

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                  TABLE OF CONTENTS CONTINUED
          Sludge Quality                                 39
     Description of Alternatives Considered by
       Metro                                             46
          Introduction                                   46
          Description of All Alternatives                47
          Metro's Screening and Selection Process        47
          Alternatives Rejected or Deferred by Metro     47
          Detailed Description of Feasible Alterna-
            tives                                        51
     Metro's Preferred Long-Range Sludge Management
       Program                                           59
          Goals of the Preferred Plan                    59
          Elements of the Preferred Plan                 60
     Metro's Preferred Near-Term Plan                    63
          Five-Year Plan                                 63
          1983 Plan                                      64
     Approach to EIS Evaluation of Alternatives          69

CHAPTER 3 - ENVIRONMENTAL SETTING AND IMPACTS OF
  ALTERNATIVES                                           71
     Introduction                                        71
     Impacts of Sludge Processing                        71
          Renton Treatment Plant                         71
          West Point Treatment Plant                     73
     Impacts of Feasible Long-Range Alternatives         73
          Impacts of No-Action                           75
          Impacts of Sludge Transportation               75
          Agricultural Application                       76
          Composting                                     83
          Silvicultural Application                      87
          Soil Improvement                               96
     Economic Impacts of Metro's Preferred Long-
       Range Alternatives                               100
          User Rates                                    100
     Impacts of Metro's Near-Term Plan                  101
     Impact Analysis of the Pilchuck Tree Farm
       Demonstration Project                            103
          Introduction                                  103
          Impacts of No Action                          103
          Construction-Related Impacts                  103
          Geology and Soils                             106
          Air Quality                                   114
          Surface Water                                 115
          Groundwater                                   125
          Wildlife                                      130
          Silviculture                                  135
          Aquatic Ecosystems                            138
          Land Use                                      139
          Population and Housing                        144
          Transportation                                147

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                   TABLE OF CONTENTS CONTINUED
                                                         Paqe
          Aesthetics                                     150
          Recreation and Access                          153;
          Cultural Resources                             1541
          Public Health                                  155

CHAPTER 4 - COORDINATION                                 168
     Introduction                                        168
     Public Participation                                168
          Information Brochure                           168
          Scoping Meetings                               168
          Notice of Intent                               169
          Preparations to Sludge Advisory Committee      169
     Comments and Suggestions Reviewed During
       Preparation of the Draft EIS                      169
     Upcoming Coordination Efforts                       169

LIST OF EIS PREPARERS                                    171

BIBLIOGRAPHY                                             175

APPENDIX A - PUBLIC HEALTH                               189

APPENDIX B - PROPERTIES OF FOREST SOILS                  213

APPENDIX C - SILVICULTURAL HISTORY PILCHUCK  SLUDGE|
  APPLICATION SITE                                       225

APPENDIX D - ENDANGERED AND THREATENED SPECIES -
  PILCHUCK TREE FARM DEMONSTRATION SITE                  227

APPENDIX E - CULTURAL RESOURCES PILCHUCK TREE FARM
  DEMONSTRATION SITE                                     239

APPENDIX F - WATER QUALITY AND GROUNDWATER DATA          261

APPENDIX G - EPA CRITERIA FOR CLASSIFICATION OF SOLID    271
  WASTE DISPOSAL FACILITIES AND PRACTICES  (40 CFR PART
  257)

APPENDIX H - DISTRIBUTION LIST                           301

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                       LIST OF TABLES

Table                                                  Page

 S-l      Impacts of Sludge Processing and Trans-        6
            portation

 S-2      Impacts of Land Application of Sludge          7

 S-3      Impacts of the Pilchuck Demonstration          9
            Project

 S-4      List of Possible Permits and Approval         11
            Required by Metro

 2-1      Metro's Past Sludge Disposal and Demon-       38
            stration Programs

 2-2      Metro Sludge Quantities 1978-1982             40

 2-3      Existing Sludge Physical, Chemical, and       45
            Microbial Quality

 2-4      Description of Long-Term Sludge Management    48
            Alternatives

 2-5      Costs of Feasible Alternatives                52

 2-6      Metro's Proposed Sludge Management Goals      61

 2-7      Estimated Truck Loads, Trips Per Day and      68
            Hauling Days, Pilchuck Tree Farm Demon-
            stration Project

 3-1      Energy Production for the Various Project     72
            Alternatives

 3-2      Projected Truck Traffic From the Renton and   74
            West Point Treatment Plants,  1980-2000

 3-3      Projected Annual Fuel Consumption for Sludge  77
            Trucking for Each Feasible Alternative

 3-4      Air Emissions From Trucking for Each          78
            Feasible Alternative

 3-5      Nutrient and Metal Contents of Municipal      85
            Sludge and Compost

 3-6      Species Suitability Classes                   92

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                 LIST OF TABLES CONTINUED

                                                     Page

         Projected Monthly Base Rates for the Long-  102
           Range Sludge Management Alternative

3-8      Construction-Related Impacts of Storage     105
           and Access Road Construction, Pilchuck
           Tree Farm

3-9      Comparison of Chemical Characteristics of   111
           the Pilchuck Tree Farm Soil and West
           Point Digested, Dewatered Sludge

3-10     Projected Loadings of Heavy Metals per      117
           Hectare, Pilchuck Demonstration Project

3-11     Hydrologic Data for Rock Creek, Kunze       118
           Creek, and North Fork of the Stilla-
           guamish River

3-12     Water Quality Data for Rock Creek and       119
           Kunze Creek

3-13     Pilchuck Tree Farm Preliminary Soil and     122
           Water Quality Monitoring Program

3-14     Metro Contaminant Monitoring Project -      123
           Parameters

3-15     Depth to Water, Hydraulic Conductivity and  128
           Water Level Elevations of Test Wells,
           Pilchuck Tree Farm Demonstration Project

3-16     Metal Concentrations in Plant Species       133
           Found on Sludge-Treated and Control
           Areas at Pack Experimental Forest

3-17     Population Changes from 1970 to 1980 in     146
           Census Tracts in the Vicinity of the
           Pilchuck Tree Farm

3-18     Quantities Which Must be Consumed at One    158
           Time to Result in Salmonellosis and the
           Time for an Average Adult to Consume
           that Quantity

3-19     Quantities Which Must be Consumed at One    160
           Time to Result in Enterovirus Infection
           and the Time for an Average Adult to
           Consume that Quantity

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                  LIST OF TABLES CONTINUED

Table
  3-20    Quantities Which Must be Consumed at One    161
            Time to Result in Ascaris/Giardia
            Infection and the' Time Required for an
            Average Adult to Consume that Quantity

  3-21    Daily Human Consumption Necessary to Cause  162
            Health Problems from Cadmium or Lead

  3-22    Quantities Which Can be Consumed on a       164
            Continuous Basis Without Exceeding
            Standards or Criteria for PCBs

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                       LIST OF FIGURES

Figure                                                Page

 2-1      The Distribution of Sludge According to      29
            the Method of Disposal

 2-2      Metro's Wastewater Treatment Plants and      32
            Sludge Transfer Facilities

 2-3      Flow Diagram of Metro's Sludge Treatment     33
            and Disposal Processes

 2-4      Existing Sites for Disposal and Reuse of     35
            Metro Sludge

 2-5      Pounds of Sludge Pumped to West Point        41

 2-6      Monthly Variation in Metro's Sludge          42
            Production

 2-7      Summary of Future Sludge Quantity            43

 2-8      Location of the Pilchuck Tree Farm,          65
            Arlington, Washington

 2-9      Proposed Sludge Application Sites and        67
            Facilities, Pilchuck Tree Farm, Arling-
            ton, Washington

 3-1      Proposed Sludge Application Sites and       104
            Facilities, Pilchuck Tree Farm, Arling-
            ton, Washington

 3-2      Geologic Features of the Pilchuck Site      107

 3-3      Surface Water Resources of the Pilchuck     116
            Demonstration Project Arlington, Wash-
            ington

 3-4      Surface and Groundwater Monitoring Stations 124
            Pilchuck Tree Monitoring Project

 3-5      Well Location Pilchuck Tree Farm, Arling-   126
            ton, Washington

 3-6      Zoning in the Project Vicinity              140

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                  LIST OF FIGURES CONTINUED

Figure                                                Page

 3-7      Projected 1990 Land Uses                    142

 3-8      Census Tracts in the  Vicinity  of the        145
            Pilchuck Tree Farm

 3-9      New Residential Development in the          148
            Project Vicinity

 3-10     Feasible Pathways of Microbial Transport    156
            Out of Sludge in a Silviculture Appli-
            cation

 3-11     Pathways of Metals Transport From Sludge    155
            in a Silvicultural Application

 3-12     Pathways for Organic Toxicant  Transport     155
            From Sludge to Environmental Compart-
            ments in Silviculture Application

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                        EXECUTIVE SUMMARY
(X) Draft Environmental Impact Statement
( ) Final Environmental Impact Statement
Type of Action:  Administrative


                   Purpose and Need for Action

     On  October 21,  1980,  Metro applied  to Washington  State
Department  of  Ecology  (DOE)  for an  amendment  to  the Step  1
construction  grant for  upgrading the  Renton Treatment  Plant.
The  amendment  will  cover  planning  for  ultimate  disposal  of
sewage  sludge  from  the  Metro   system.   The  original  Renton
facilities  plan included  an  element  for  removal  of  Renton's
sludge from Metro's West Point Treatment  Plant,  where it is now
sent  for  processing,  and construction of processing  facilities
at  Renton.   This  will fulfill  a commitment,  made  in  earlier
facility  planning  efforts,  to remove Renton sludge  from  West
Point  and thereby  reduce  the  load on  West Point  facilities.
However, the Renton plan did not cover ultimate sludge disposal.
Planning  for  sludge disposal  has proceeded  within Metro  as  a
separate effort to the  Renton  facilities  plan.   Since the  U.  S.
Environmental  Protection Agency  (EPA)  and  Washington DOE  had
previously considered  sludge disposal to be a  logical  part  of
Renton planning,  and since  Renton  planning  was already on the
state  priority  list,   sludge  disposal   planning  was  made  an
amendment to  the  existing grant  rather  than a  separate grant.
The  EPA Environmental  Impact Statement   (EIS)   for  the  Renton
facilities plan discusses  proposed  sludge processing  facilities
at  Renton  and  the impacts  of  construction  and  operation.   The
EIS  also  briefly  summarizes ongoing  Metro  planning  for sludge
disposal,  but  does   not  analyze  environmental   impacts  of
disposal.  Agreement was reached between Metro and EPA, prior to
the  grant amendment  request, that EPA would prepare  a separate
EIS on sludge disposal.

     Metro  has  prepared  a  sludge  management  plan  for  the
following reasons:   1)  a  plan for sludge  use  is  important  to
ensure proper treatment design at the Renton Treatment Plant;  2)
Metro's 1980 facilities plan for  the Renton  Treatment Plant did
not include a comprehensive  evaluation of sludge management and
disposal; 3)  a  sludge management plan is a required component of
the  National  Pollutant Discharge  Elimination  System  (NPDES)
permit  requirement  for the  Renton  and  West  Point  Treatment
Plants;  4)  future capacities  to recycle  or dispose  of sludge
through the year 2000 need to  be  assured;  and 5)  Metro needs to
identify a cost-effective means of managing sludge.

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     Although  federal  funding  has been used for  preparation of
the  sludge  management plan, no  federal funding  is  anticipated
for  design   or   construction   of  the  sludge   processing  or
application facilities or  for  any proposed facilities upgrading
at the Renton Treatment Plant  (Riley pers.  comm.).


             Role of Environmental Impact Statement

     This EIS  focuses  on two distinct  facets of  Metro's sludge
management  plan:   the environmental  impacts of  Metro's sludge
management  alternatives,   and  the   environmental  impacts  of
Metro's  proposed sludge  application  demonstration   program on
forestlands of the Pilchuck  Tree Farm, Arlington,  Washington.
EPA  has  determined  that   this  EIS  is  required to meet  the
requirements  of  the National  Environmental Policy  Act  (NEPA).
This EIS  will also  satisfy Metro's  responsibilities  under the
Washington State Environmental Policy Act  (SEPA)   (RCW 43-21C).
                   Description of Alternatives
Background
     From  1965  to 1972, Metro discharged  sewage sludge through
the West  Point  effluent outfall into  Puget  Sound.   That method
of sludge disposal was  terminated in 1972 as a result of federal
and state  regulations  prohibiting  the  ocean disposal of sludge.
From  1973  on,  Metro initiated a program  of land application of
sludge  on demonstration and  research  sites  throughout western
Washington, and a composting program with GroCo, Inc.  Among the
research  projects were  forestland  application at the University
of  Washington's Pack  Research Forest,  Eatonville,  Washington,
and   agricultural   application   at   Mt.   Vernon  and  Puyallup,
Washington.   Results of Metro's forestland  sludge  application
research  have provided  insight into seedling growth and survival,
tree  growth  in  established  forests,  and   impacts  of  sludge
constituents.

     During the past 5  years,  the  volume of sludge generated at
Metro's  Renton  and  West Point  Treatment Plants  has  increased
approximately  85  percent.    Approximately  49   percent  of  all
sludge  generated  during the past 3 years has been  applied as a
top  dressing  at the Cedar  Hills landfill,  32  percent  has been
transported to  WIDCO for use in reclaiming surface-mined lands,
and  the  remaining  19   percent  has  been  utilized  for  either
composting  at  GroCo,   Inc.,  or land  application  at   the  Pack
Research  Forest,  at the Duvall  and Midway  landfills,  and  at a
number  of  small soil improvement sites in the King County area.

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     Metro  projects  that the  quantity of  sludge  will increase
from 35 dry tons  of  digested  sludge  per day in 1982 to slightly
over 60 dry tons  per day in 1990,  and to 80 dry tons per day by
the  year  2000  (Metro  1983a).    The  physical,  chemical,  and
microbial quality of the sludge  has  been extensively studied by
Metro.  An intensive monitoring program was carried out from May
1981 to May 1982 to determine the concentrations  of nutrients,
trace metals, trace  organics, and bacteria in the sludge, and to
provide insight  into  possible  constraints that  sludge quality
may  create  for different  management alternatives.   Results  of
those studies are discussed in Chapter 2.


Long-Range Sludge Management Alternatives

     Metro  initially identified  18  project  alternatives  within
eight  broad  categories  of  sludge  management:   agricultural
application,  composting,   dry   sludge  product,  incineration,
landfilling, ocean disposal, silviculture, and soil improvement.
Of  the  18  initial  alternatives, Metro  eliminated   five  from
further  consideration  because  of  high  costs  or  unacceptable
nonmonetary   factors.   Metro   also   "deferred"   four   other
alternatives   as    not   presently   feasible   for   near-term
implementation,  but  which  might  at  some  later  date be  more
closely considered.

     The remaining  9 alternatives  were recommended  by Metro for
additional evaluation.  These alternatives were:

     o  Agricultural application
        - Alternative  1
     o  Composting
        - Alternative  2A - tank composting
        - Alternative  2B.1 - pile composting, 18 percent solids
     o  Silvicultural  application
           Alternative  7A  -  public/private  forestlands  with
        Metro-owned  demonstration site
        - Alternative  7B - Metro-owned poplar forestlands
        - Alternative  1C - Metro-owned multiple use forestlands
           Alternative  7D  -  public/private  forestlands  with
        Metro-owned  backup site
     o  Soil improvement
        - Alternative  8A -  soil improvement of public/private
        land
        - Alternative  8B - soil improvement at WIDCO

     Although 9  of  18 original alternatives  were  identified  as
"recommended", Metro's sludge management plan did not identify any
single  specific  alternative,  or  any  single  combination  of
alternatives,  as  preferred.   Rather,  Metro  identified  land
application   of   sludge   through   agricultural   application,

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composting, silvicultural application and/or soil improvement to
be the preferred management strategy.  Metro further recommended
that  anaerobic  digestion  with  medium  dewatering   (18  percent
solids) be  the preferred  sludge  processing method  at  both the
Renton and West Point Treatment Plants.

     This EIS  focuses  on the impacts  of the preferred strategy
(agricultural     application,     composting,     silvicultural
application, soil improvement)  and  the impacts of the 9 project
alternatives previously  described.   The  no-project alternative
is also evaluated, as required by EPA regulations.


Near-Term Plan

     As  components  of  the 20-year  planning  effort,  Metro has
identified  the  need  for  5-year and  1-year  sludge management
plans.   The  goal  for  sludge   utilization  during  the  5-year
planning period was as follows:

     Agricultural application        15  percent
     Composting                      15  percent
     Silvicultural application       25  percent
     Soil improvement                45  percent

Because  a  specific  5-year plan  has  not yet  been  completed by
Metro, it has  not been evaluated  in this  Draft EIS.

     Metro's proposed  1-year (1983) plan would  include the use
of five sites  which  have been granted requisite permits  (WIDCO,
Pack Forest,  GroCo,  and Cedar  Hills  and Duvall landfills), the
Pilchuck  demonstration  project  (permitting  in  progress), and
other  unidentified sites to accommodate  the estimated 77,700 wet
tons of sludge to be produced in  1983.   The five permitted  sites
are not  evaluated  in this EIS because they  have been previously
evaluated  to  meet  SEPA  requirements,  and because  no  federal
funding  for these  sites  is  proposed.    A  detailed analysis of
impacts  associated  with  sludge  application  on  the  Pilchuck
demonstration  project has  been  included  in  the EIS.


Subsequent Metro Planning

     Metro  has  indicated  that  more detailed sludge management
planning will  be undertaken  during  the time period of the  draft
and  final  sludge management  plans (Metro letter to  DOE December
20,  1982).   Additional  information  in  the  final  plan  is to
include the  following elements:

     o  1984 sludge utilization goal
        - Where  possible sites, hauling  distances,  acreages, and
          application rates would be identified
     o  1984-1988 sludge utilization goal
        -  A more detailed description of the 5-year plan  would
          be provided

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     o  Year 2000 sludge utilization goal
        - Metro would recommend sludge utilization targets to
          the year 2000
        - The plan will outline criteria for achieving long-term
          commitments for use of Metro Sludge
     o  Contingency plan
        - The final plan would include the possibility of using
          Cedar Hills landfill or construction of a sludge
          storage lagoon
     o  Financial plan
        - This section will estimate the level of effort
          required to implement the 1983, 1984, 5-year, and year
          2000 utilization goals and the contingency plan
     o  Public involvement
        - A discussion of procedures Metro will follow for
          future sludge utilization sites will be presented


                      Assessment of Impacts

     The environmental impacts'and potential mitigation measures
of  the four  broad  sludge  management  categories  (agricultural
application, composting, silvicultural use and soil improvement)
are  summarized  in  Tables  S-l   through S-3.   Only  the  more
significant  impacts  have   been   summarized.    The  mitigation
measures listed are possible methods of avoiding or reducing the
severity of adverse  impacts, but  are  not necessarily those that
would  be  implemented should  a  project be  constructed.   The
adopted mitigation measures will  be  included  in EPA's Record of
Decision on the  project  which will be prepared after completion
of  the  Final  EIS.   EPA  will  not  be  responsible  for  all
mitigation  measures   required.   Local  and  state agencies  will
suggest  or  require   those  mitigations  that   are  within  their
respective functional capacities.

     An  analysis of  the impacts  associated  with the  Pilchuck
demonstration project is also presented following the assessment
of impacts of the long-range options.

     As  part  of  the planning regulatory  process,  Metro  would
need to obtain permits and  approval  from a  variety  of state and
local  entities.   A  list   of  those  permit  requirements  is
presented in Table S-4.


Impacts of No Action

     The  "no-action" alternative  would  essentially  mean  that
Metro would continue  year-by-year  planning  which  would create a
situation whereby  Metro  may not  have adequate  flexibility  and
contingencies in the  event  established sludge application sites
could  no  longer be  utilized.   Additionally,  the NPDES  permit
which requires an  approved sludge management plan would  not be
met.

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                         Table S-l.   Inpacts of Sludge Processing and Transportation
Type of Impact
Description of Impact
Mitigation Measure
Site impacts at Renton treat-
ment plant
Energy consumption
Site impacts at West Point
treatment plant


Sludge-haul truck traffic
These impacts were previously
analyzed in EPA's EIS on the
Wastewater Management Plan for
the Lake Washington/Green River
Basins

Depending on the alternative and
the hauling distance, year 1990
fuel consumption for trucking
would vary from 24,455 to 462,455
gallons.
Minor construction impacts only
with Alternative 2A  (Taulman-
Vfeiss tank composting)

Increases in sludge hauling
traffic from the Renton treat-
ment plant from no trucks/day
in 1983 to 9/day by the year
2000; increases fron 9 trucks/
day in 1983 at West Point to
13/day by 1987, than a decrease
to 9/day by 2000.
Mitigation measures were
identified in the Renton EIS
Less fuel would be required for
application sites close to the
Metro treatment plants.  When
total energy consumption is con-
sidered, more energy would be
produced by methane gas (heating,
generation of electricity) than
would be consumed.

Standard construction-related
mitigation measures for dust
suppression, traffic and noise
None required.

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                                         Table S-2.  Impacts of Land Application of Sludge
Area of Impact
Description of Impact
Mitigation Measures
Soils
Land use
Vegetation and crops
           Impacts of Agricultural  Application

Increase in organic content of soil;  in-
creases in heavy metal content of soil;
annual loading of cadmium of 0.32 kg/ha
(0.28 Ib/ac);  increases in nitrogen to
soil of 98 Ibs/ac/yr.

Cadmium loading at the estimates of
0.32 kg/ha/yr would not limit future land
use of the site (even for growing food
chain crops) so long as cumulative cad-
mium loading would not exceed 5-20 kg/ha
(as determined by soil cation exchange
capacity, CEC).

Uptake of heavy metals by plants would
occur in varying amounts.
Lime soils to achieve a pH of 6.5 or
greater; follow DOE BMPs for the Use
of Sewage Sludge.
Cumulative cadmium loading must conform
to EPA regulations (40 CFR 257) as
determined by the CEC of the soil.
Limitations to the crops grown should
be based on 40 CFR 257 and DOE BMPs.
Land use
Worker exposure to com-
posted sludge
Water quality
Public health
                 Impacts of Composting

Development of a composting facility
would generally be compatible with in-
dustrial land uses; residential areas
peripheral to the site could be adversely
affected by composting activities.

Continual exposure to sludge compost could
cause aspergillosis or uptake of pathogens
from aerosols.
Runoff from composting site could cause
impacts on surface water or groundwater.


Heavy use of composted sludge by home-
owner for growing vegetable could cause
a buildup of heavy metals in the
soil.
                                                                                           Consideration should be given to design-
                                                                                           ing the site to minimize light, glare
                                                                                           and noise if sensitive receptors are in
                                                                                           the vicinity.
Maintenance of high internal composting
temperatures  (130°F-150°F) would reduce
pathogens; use of breathing masks and
enclosed cabs on composting vehicles
could reduce worker exposure; sprinkling
site should be done to reduce dust.

Site should be designed with an imper-
vious surface area and runoff collection
system connected to a sewer.

Future regulations will dictate ultimate
use of composted material; labeling for
consumer protection could be provided on
compost bag.
Geology and soils
         Impacts of Silvicultural Application

Improvement in the texture of coarse
soils and reduced susceptibility of
soil to erosion; slight, temporary de-
crease in infiltration rate; changes in
pH followed by slight increase; increase
in organic matter; increase in essential
plant nutrients; increase in heavy metals
content.
Use of DOE BMPs to identify proper sites
for sludge application.

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                                                              Table S-2.  Cont'd.
      Area  of  Impact
Description of Impact
Mitigation Measures
      Silviculture
       Surface and groundwater
      Terrestrial wildlife and
      aquatic life
Increase in growth response of Douglas-
fir, sitka spruce, poplar and cottonwood;
possible damage to buds of young Douglas-
fir seedlings.

Potential for nitrate and, depending on CEC
of soil, heavy metal and pathogen movement
into water; possible contamination of a
drinking water supply.
See Table S-3.
Application of sludge well before bud-
burst in the spring.
Where possible,apply sludge on a site
with an isolated aquifer and not used  as
a drinking water supply; to limit ni-
trate leaching apply sludge at a rate
necessary to meet the nitrogen require-
ment of the forest.  Follow DOE BMPs.

See Table S-3.
      Soils
      Land use
CO
      Groundwater and surface
      water
              Impacts of Soil  Improvement

Increase in organic and nutrient content
of mineral soils; improved soil stability
and texture.

Location of storage lagoons or applica-
tion areas may adversely affect surrounding
land uses; proposed use of sludge on
gravel pits, surface mines, powerline
rights-of-way and landfills may inter-
fere with primary day-to-day use of
sites .

Leaching of nitrates and heavy metals and
movement of pathogens and organics may
impact groundwater and surface water
resources.
                                                                                                 None needed.
Selection of sites remote from sensitive
visual and odor receptors; careful
selection of application sites and
development of an operations plan for
Metro and the site user.
Where groundwater is now or may possibly
be a drinking water source in the future,
surface water monitoring stations should
be established above and below area of
sludge application; groundwater monitor-
ing should be both up-gradient and down-
gradient of a sludge-treated area (DOE
l<»82a) .

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                                     Table S-3.  Impacts of the Pilchuck Demonstration Project
Area of Impact
Description of Impact
Mitigation Measures
Soils
Surface water
Groundwater
Wildlife

Silviculture



Aquatic ecosystems

Transportation
                                      Compaction on roads and trails by
                                      application vehicle.
                                      Temporary reduction in soil infiltration.
                                      Improvement of soil structure.
                                      Increase in soil nutrients.
                                      Fluctuations in soils pH.
                                      Increase in heavy metals content of top
                                      4-6 inches of soil.
                                      Possible direct spraying of sludge into
                                      creeks.
Possible accidental spills into creek.

Runoff off site into surface water.

Nitrate leaching to groundwater.


Possible impact from rainwater spray site.
Direct sludge ingestion, bioaccumulation,
and possible chronic toxicity to wildlife.
Increases in growth response to trees
and understory vegetation.
Potential minor changes in wood quality.
Small likelihood of adverse effect on fish
populations.
Increase in opportunity for traffic
accidents on Armstrong Road.
                                      Increase in deterioration of Armstrong
                                      Road.
Sludge vehicle travel routes should be
carefully selected.
Design and maintenance of skid roads to
reduce ponding of water.
None needed.
None needed.
None needed.
None needed.
Limiting sludge loading per acre to
allow for even the most restrictive
(agriculture) future land use.
Place road network no closer than 150
feet from cliff edge.
High visibility markers should be
located at edge of buffer zone.

Check structural integrity of Kunze
Creek bridge.
Cease sludge application if ground
should freeze.
Groundwater movement away from drinking
water source.  Groundwater monitoring
program as proposed by Metro.
Establish best location for site based
on groundwater information.  Establish
monitoring well down-slope of spray
application site.
None.

None required.
Utilize measures previously described
for Surface Water .
Improvement to Armstrong Road advance
warning signaling device to ensure that
it functions properly.
Road sign installation warning motorists
of wide load vehicles using Armstrong
Road.

Metro coordinate with Snohomish County
to establish cooperative maintenance
checks and repairs.

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                                                        Table S-3.   Cont'd.
Area of Impact
Description of Impact
Mitigation Measures
Aesthetics
                                      Sludge-blackened trees,  occasional  odors
                                      and noise.
Recreation




Cultural resources


Public health
Area closed to recreational uses  for
13 to 20 months.
Small likelihood of encountering cultural
resources during construction activities.
Potential impact on groundwater and
surface water.
                                      Aerosol drift.
Site isolation would reduce many of
impacts.
Sludge spraying closest to residences
limited to calm days or when winds are
from the north or northeast.
Possible increase in width of the north-
ern buffer zone.

Changes in truck hauling or operation
schedules if problems with proposed
schedule arise.
Greater use of remaining Pilchuck Tree
Farm lands for recreation; adequate
posting to warn recreationists away from
site.

Notify archeologist if cultural re-
sources encountered.

Groundwater trending away from drinking
water supply.

Initiation of monitoring program as
defined by Metro.

Limit sludge spraying closest to resi-
dential areas to calm days or days when
prevailing wind is away from residential
areas.
                                      Effect of sludge on edible mushrooms  and
                                      berries.
                                                     Utilize  results  of  studies  to  determine
                                                     if  site  should be closed  to picking
                                                     berries  and mushrooms.

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   Table S-4.  List of Possible Permits and Approval Required
                            by Metro
STATE AND LOCAL
PERMITS AND APPROVAL
Department of Ecology
Office of Archeology and
 Historic Preservation

Departments of Fisheries and
 Game

Snohomish Health District,
 Environmental Health Division
State Environmental Policy Act

201 Facilities Plan Approval
 Section 201-PL92-500/Clean Water
 Act

Shoreline Management Permit

State Waste Discharge Permit
 NPDES Permit

Project Approval
Hydraulic Permit (already issued)
Land Application of Sludge Permit
                               11

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                       Public Involvement

     Public participation for this EIS has been coordinated and,
where   possible,    integrated   with   the   full-scale   public
participation program undertaken by Metro in preparing its Draft
Sludge  Management   Program.    Key   EIS   public  participation
activities have included publication  and  distribution of an EIS
information brochure,  conducting  scoping  meetings,  and  an EIS
presentation to the Citizen's Advisory Committees.

     This  Draft  EIS  has been  forwarded  to numerous  federal,
state  and  local   agencies,  special  interest  groups,  private
citizens, and  public  libraries  to act as  both  an informational
document and as an avenue to comment  on  the proposed wastewater
project.   (The Draft  EIS mailing  list is  presented  in Appendix
H).

     Individuals  or groups  that wish  to comment  on  the  EIS may
forward written comments to:

              U.  S. Environmental  Protection Agency
                            Region 10
                        1200 Sixth Avenue
                   Seattle,  Washington  98101
                  Attention:  Kathryn  Davidson

     Comments should be sent by:   May  30,  1983.

     Joint  public  hearings  have  been  scheduled  on the  Draft.
Sludge Management  Plan and Draft EIS by  Metro and EPA.


During these public hearings, formal  oral  and written testimony
will be received.
                               12

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	Chapter 1
                           Introduction
•Environmental Impact Statement Requirement
           •Metro's Sludge Management Plan
                             •EIS Context
                       •Public Participation
 •Legal, Policy, and Institutional Considerations

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                            Chapter 1
                          INTRODUCTION
           Environmental Impact Statement Requirement

     The  Municipality  of  Metropolitan   Seattle   (Metro)   has
prepared  a  Draft  Sludge Management  Plan  for managing  sewage
sludge  produced  at the  Metro wastewater  treatment  facilities.
This  Draft  Environmental  Impact   Statement   (EIS)   has  been
prepared  by  the Environmental  Protection Agency  (EPA),  Region
10,  to   assess  the   Sludge   Management  Plan's  environmental
consequences.

     The  relevant  EPA  decisions   are  to  approve  the  Sludge
Management  Plan,   the  preparation   of  which   is   partially
federally funded,  and  to partially fund  projects  called  for in
the  plan.   This   EIS   satisfies   EPA's   environmental  review
responsibilities  under the  National  Environmental  Policy  Act
(NEPA),  and  will   be   used   to  satisfy  Metro's  environmental
review    responsibilities    under    the   Washington    State
Environmental Policy Act (SEPA).


                     Organization of the EIS

     This Draft  EIS consists  of a  main  text  and accompanying
technical appendices.   This  chapter,  Chapter  1,  discusses  the
purpose and need for Metro's  Sludge Management  Plan;  describes
the organization and  context  of the EIS;  summarizes  EIS  public
participation  activities;  and defines  relevant  legal,  policy
and institutional considerations.

     Chapter  2  of  the EIS   provides  an  overview  of  sludge
management concepts,  a description  of Metro's  existing  sludge
management methods,  sludge  quantity and  quality,.a  description
of alternatives considered by  Metro, an overview of  composting,
silvicultural  application,  agricultural  application  and  soil
improvement,  and a description of Metro's preferred plan.

     Chapter 3 describes the  environmental  setting and assesses
the impacts  of Metro's  sludge management alternatives for  the
20-year preferred  plan  and  for the Pilchuck  sludge  application
demonstration project.

     Chapter  4  identifies  EIS coordination  activities  and is
followed by a list of EIS preparers and the bibliography.
                               13

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     Seven technical appendices have been prepared which present
detailed  information  on public health  (Appendix  A) ,  properties
of  forest  soils   (Appendix   B) ,   silviculture  (Appendix  C) ,
endangered  and   threatened  species   (Appendix   D) ,   cultural
resources  (Appendix  E),   water  quality  and  groundwater  data
(Appendix F),  and the distribution list (Appendix G).
                 Metro's Sludge Management Plan
Purpose and Need
     Metro  has  prepared  its  Sludge  Management  Plan  for  the
following reasons:

     1. Prior  recent Metro  wastewater  facilities plans, includ-
        ing  the 1980  Wastewater  Management  Plan for  the Lake
        Washington/Green  River  Basins   (covering  Metro's Renton
        Treatment  Plant),  did   not   include  a  comprehensive
        evaluation of sludge management and disposal.

     2. A  plan  for  sludge  use  is important to  ensure proper
        treatment system design at the Renton Treatment Plant.

     3. A sludge management plan  is a  required component of the
        National Pollutant  Discharge Elimination System (NPDES)
        permits issued by DOE.

     4. Future  capacities to  recycle  or  dispose of  projected
        year 2000 sludge quantities should be assured.

     5. Through  the  planning  effort,  Metro  needs  to identify
        cost-effective sludge management alternatives.


Development of the Sludge Management Plan

     Metro's current sludge management  planning has  been influ-
enced by a number of previous  actions  and  planning efforts.   In
1965,  a decision was  made to  transport  sludge by force main
from  the  Renton  Treatment  Plant  to  the  West  Point  Treatment
Plant  for  treatment and  disposal.  Because  of  that  decision,
all  sludge  handling  and disposal  from  1966 to  the  present  has
been  through  the West  Point  plant.   In  Metro's  Wastewater
Management  Plan  for   the  Lake  Washington/Green  River  Basins
(1980), recommendations were  made to  provide  solids handling
facilities  for sludge  digestion  and dewatering at the Renton
Treatment Plant.  Construction of  those facilities is  scheduled
to begin in mid-1984.

     The  process  for  preparing  the  current  Draft  Sludge
Management Plan  is  described in  detail in Metro's  draft  plan,
and will therefore only be  summarized  here.   The following is a
chronological order of  reports  and events leading to  the  draft
plan:

                               14

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     1. December  1980:   Preliminary  Draft  cost-effectiveness
        analysis of system-wide sludge management alternatives.

     2. June  1981  -  May  1982:   Technical  memoranda on  site
        selection criteria,  soil  improvement, silviculture, and
        urban distribution.

     3. July 1981:  Creation of Citizens Advisory Committee.

     4. August 1982:  Preliminary Draft Sludge Management Plan.

     5. September 1982:  Preliminary Draft report, Pilchuck Tree
        Farm demonstration sludge application project.

     6. November   1982:    Revised   Preliminary  Draft   Sludge
        Management Plan.

     7. December  1982:    Revised   sludge   disposal  and  reuse
        cost-effectiveness evaluation.

     8. January  1983:   Draft Risk Analysis,  Pilchuck Tree Farm
        demonstration sludge application project.

     In March 1983, Metro will issue its Draft Sludge Management
Plan  for public  review and  comment.   That  plan  will  include
discussions of sludge management issues, sludge characteristics,
alternatives  considered,   recommended  long-range and near-term
plans, and public participation.

     Metro's plan  covers  a  15-year  planning period,  while the
near-term plan  covers  5-year and 1-year planning periods.   The
sludge management plan includes long-range sludge management goals
focusing   on   soil   improvement,   agricultural   application,
silvicultural  application  and  production,  and  marketing  of  a
composted sludge  product,  the 5-year plan  covers the following
subject    areas:     planning    objectives,   quantities    and
characteristics  of  sludge,   project  identification  methods,
project evaluation  procedures,  and  project  implementation.   The
1-year  plan  identifies  specific  projects   for   which  approval
will be sought by Metro during the next year.


                           EIS Context
Major Issues Addressed by EIS

     Preparation  of the  Sludge Management  Plan  has raised  a
number of  important issues.  Based  on public input  during the
scoping  process  and  consultation  with  affected  agencies,  the
following  issues  have  been   determined   to  be  of  greatest
importance to this EIS:
                               15

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     1. Completeness in the range of alternatives considered.

     2. Relationship of the sludge management plan to Metro's near-term
        sludge disposal activities.

     3. Cost of sludge disposal alternatives.

     4. Local  jurisdictional  authority  over  sludge  disposal
        outside Metro's service area.

     5. Impact of federal and state regulations.

     6. Ability to demonstrate the benefits of sludge reuse.

     7. Impact  of  sludge  transportation  on  traffic  congestion
        and circulation.

     8. Risk  of  accidental spills during  sludge  transportation
        and disposal.

     9. Impact of  sludge  disposal on surface water  and ground-
        water.

    10. Public access and recreation at disposal sites.

    11. Effect of future land use changes or land use restri-
       ctions on sludge disposal sites.

    12. Effect of sludge disposal on public health.

    13. Effect of sludge disposal on fish and wildlife
        resources.

    14. Aesthetic impacts of sludge disposal including odor and
        noise.

    15. Monitoring and mitigation measures for sludge disposal
        sites.

    16. Effect of sludge application on timber management
        practices.

    17. Effect of sludge application on insects and other inver-
        tebrates .

    18. Effect of sludge application on mushrooms and other
        edible wild foods.

     The EIS  emphasizes the above  issues,  but also  covers the
entire range of biophysical and socioeconomic impacts related to
Metro's near-term and long-range alternatives.
                               16

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                        Public Participation

     The  public participation  program  for this  EIS  has  been
coordinated   and,   where  possible,   integrated   with  Metro's
extensive public participation program for its Sludge Management
Plan.

     The  EIS process  for  Metro's Sludge  Management  Plan  was
initiated in July  1981.   On November  6,  1981,  EPA published in
the  Federal  Register its Notice  of Intent to prepare  the EIS.
On  December  9,  10,  15,  and  16,  1981,  public   EIS   "scoping"
meetings were held  in  conjunction with Metro public information
meetings in  Orting, Arlington, Seattle, and Belfair, Washington.
A  responsiveness  summary  of public  comments  and  responses  to
questions received  at the  "scoping"  meetings was  prepared  and
distributed  in April 1982.

     Joint   Metro   and   EPA  public  information   meetings  are
scheduled to be held May 3 and 5, 1983 in Seattle and Arlington,
Washington.   The  purpose of those  meetings will  be  to present
the  proposed project and impact  analysis to the  public  and  to
answer any questions the public might have.

     Public   hearings  on  the  Draft  EIS   and   Draft  Sludge
Management Plan are currently scheduled for May 15 and  17, 1983.
Based  on public input,  the Draft  EIS and  draft plan will  be
revised, and  final versions of the documents will be released in
the  fall of  1983.   A Metro  decision on the final  plan will then
be made.   Subsequently,  EPA and DOE  will take  approval actions
on  the  final  plan.  A  facilities  design grant  will be  made
according to  state funding priorities.

     The  Draft  EIS  comment  period,  the  public  hearings  to  be
held on  the  Draft  EIS, responses to  comments to  be included  in
the  Final  EIS,  the  comment period  for  the  Final EIS and  the
response  to  comments  in the  Record  of  Decision  will fulfill
EPA's  remaining  formal   public  participation  responsibilities
under NEPA.
           Legal, Policy, and Institutional Considerations

     EPA  is  required to  integrate  EIS  preparation  with  the
requirements  of  other environmental  laws and  executive  orders
(40 CFR  S1502.25;  40 CFR  S6.300);  to identify  in  EISs  federal
permits,  licenses  and entitlements  which must be  obtained  to
implement  an  action  (40 CFR  1502.25);  and to  identify  in EISs
inconsistencies  of  an action with  state and  local plans  and
laws (40 CFR S1506.2).  The purpose of this section is to review
federal,  state  and local  environmental  requirements which  are
relevant  to either  alternatives considered  in Metro's  Sludge
Management Plan or to this EIS.

     Of  the various  environmental  requirements,  some will  be
complied with as part of preparation of  Metro's Sludge  Manage-
ment Plan  or  this  EIS.  Others  can only  be  complied  with when
Metro proposes specific  future projects  pursuant to the Sludge
Management Plan.

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Federal Requirements Relevant to Sludge Management and Disposal

     Clean Water  Act  (42 USC S1857 et  seq.).   The goals of the
Act are to achieve "fishable,swimmable" surface waters through-
out  the  nation  by  1983,  and  to  achieve  no  discharge  of
pollutants by  1985.   Section 201 of the Clean Water Act estab-
lishes  a  construction grants  program  for  municipal wastewater
facilities, wherein federal grants are offered for the planning,
design,  and  construction  of  publicly-owned  treatment  works.
This  funding  is  75  percent  (85  percent  for  innovative  and
alternative  technology  projects)  of  the  eligible  costs  of
municipal  wastewater  treatment   plants and   sludge  management
facilities.  Metro's Sludge Management Plan has been funded with
a Step  1 construction grant.

     Section  208  of  the  Act   establishes  an  areawide  waste
treatment  management  planning process;  Section 208  plans  must
develop controls  for both  point  and  nonpoint sources  of water
pollution.   Under Section 303 of  the  Act, states  are required
to  prepare and enforce  ambient  water  quality standards  and to
prepare basin  plans showing  how these  standards  will  be  met.
Metro's Sludge Management  Plan must be  consistent  with areawide
and state water quality management plans.

     Under Sections  401  and 402  of  the Act,  EPA  or  the states
are  required to  issue NPDES  permits for  all  point  sources of
pollution.   NPDES  permits   for   wastewater   treatment  plants
include   sludge   disposal   conditions   where  possible,   thus
reducing the need for separate sludge disposal permits.

     Several portions  of the Act relate specifically  to sewage
sludge  management.   Section 405(d) requires  EPA  to" promulgate
guidelines and  regulations for sewage  sludge  disposal.   Pursu-
ant  to both  this  section  and   requirements  of  the  Resource
Conservation and  Recovery Act (RCRA),  EPA has issued Criteria
for  the Classification of  Solid  Waste  Disposal Facilities  and
Practices  (Criteria) (40 CFR Part  257) .  The Criteria set forth
specific requirements  for  protection of floodplains,  endangered
species, surface  water,  groundwater, sludge  application  to  land
used  for  production of  food-chain  crops,  disease  vectors,  air
emissions, and  safety.  They  regulate  all land-based  alterna-
tives   for   sewage   sludge  disposal,   including   landfilling,
nonagricultural land  application,  and agricultural  land appli-
cation.   Sludge  management projects   implemented  pursuant  to
Metro's  Sludge Management Plan  must  be  consistent  with  the
Criteria.

     Under authority  of  Section   405(d), EPA  is also  currently
developing regulations (40 CFR Part 258) for  the  public distri-
bution  and  marketing  of  sewage  sludge-derived  fertilizer
products.   Other  portions  of the Act related  to  sludge  manage-
ment include  Section  307, which  encourages  the utilization of
sludge by  requiring  pretreatment of industrial wastes  entering
publicly-owned  treatment   works.    Metro   has  implemented  a
pretreatment program pursuant to  the Act.
                              18

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     The Resource Conservation and  Recovery  Act (42 CFR 3251 et
seq.).   RCRA  establishes  national  policies  and  programs  for
solid  waste management,  in  general,  and  for  hazardous  waste
management,  in   particular.    With  respect   to  solid  waste
management,  the  Act prohibits new  open  dumping sites, requires
that all  open  dumping sites be  converted  to sanitary landfills
or  closed  by   1983,   and  authorizes  the  preparation  of  the
Criteria   previously   reviewed.    The   Act   further  provides
financial  assistance  for the development  and  implementation of
comprehensive  state  solid  waste management plans,  which are to
include  environmentally-sound  disposal  methods  and  resource
recovery programs.

     Subtitle  C  of  RCRA  establishes a  program for comprehensive
"cradle-to-grave" regulation of  hazardous  wastes.  RCRA hazard-
ous waste  regulations do  not apply because Metro's  sludge is
not  classified  as  a  hazardous  waste,   based  on  testing  for
contaminant  levels.

     The Clean Air Act (42 USC 1857 et seq.).  The Clean Air Act
(CAA)   sets the  basic  framework for  federal,  state,  and  local
air  quality  management  programs.   The  major  implementation
provision  of  the  CAA  requires  each  state  to establish  and
implement  a plan to achieve  federal ambient  air  quality  stan-
dards  within  specified   time   frames.    The   resulting  State
Implementation Plans  (SIPs)  provide the  regulatory programs for
controlling  pollutant   emissions   from   existing   and   future
sources.   EPA  procedures  require   the  agency  to  consult  with
appropriate  state and local  agencies when  a  proposed action may
have  a  significant effect  on  air  quality  to determine  the
conformity  of  the   action  with the  applicable  SIP   (40  CFR
S6.303) .

     The  Act  provides  for  two sets  of  national  ambient  air
quality  standards,  primary  standards  (for the protection  of
human  health)  and  secondary standards  (for  the protection of
other  values  such   as  crops   and  materials).   The  Act  also
provides for national  emissions standards for  hazardous pollu-
tants,  and  for  new  source  performance  standards  for  certain
industrial categories.

     Areas which exceed any federal primary air quality standard
(nonattainment areas)  are  required by the Act  to  control  both
existing  and  new  emission  sources  so  as  to  achieve  annual
incremental  reductions in  pollutant  emissions  until the  federal
standards  are  met.   The  Act requires  states  to  establish  new
source review  programs  for major new stationary  sources  and to
establish  a  program for  prevention  of  significant deterioration
in areas that currently meet national ambient standards.

     Incineration and  thermal reduction of  sludge must meet  a
number   of   CAA   requirements.    Most   importantly,    these
alternatives must comply  with   SIP  emission  limitations,  with
national emissions standards for hazardous pollutants, and with
new source performance standards.
                               19

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     Marine  Protection,  Research  and Sanctuaries  Act  (33  USC
1401 et seq.)~Underthislaw,ocean dumping  ofsewagesludge
after  December  31, 1981   is   prohibited.   The   Metro  Sludge
Management Plan is consistent with the Act because ocean dumping
of sewage sludge is not proposed.

     Safe Drinking  Water  Act  (42  USC 300f et  seq.).   This law
establishes  the  national  program  for protecting  drinking water
supplied by  municipal  and  industrial water suppliers.  Pursuant
to  the Act,  EPA  has  issued  national  primary  drinking  water
standards  to protect  human health  (40   CFR  Part  143).   These
standards are minimums to  be  adopted by  the  states and applied
to  municipal and  industrial  water  suppliers.   Under  the  Act,
states with  approved programs  have  the  primary  implementation
and enforcement authority.

     Section 1424 (e) of the Act authorizes EPA to determine that
an  underground  aquifer is  the  "sole source" of  drinking water
for an area  or community.   Once  an aquifer is  so  designated, no
federal  financial assistance  is  available  for  projects  which
may contaminate  the aquifer.  Sole source aquifers  in the State
of  Washington  include  the  Rathdrum  Prairie   Aquifer east  of
Spokane, and the Whidbey and Camano Islands aquifers.

     Section  1442  of  the  Act  requires  states   to  conduct  a
"Surface Impoundment Assessment" to  locate all  surface impound-
ments  (pits,  ponds,  and  lagoons)  and assess them for pollution
potential.  The Washington DOE has completed this  assessment.

     Lastly,  Section  1421  of  the Act  authorizes  state  under-
ground  injection  control  programs.    The  state  program  would
apply  if  sludge  is injected into  the ground or abandoned wells
or mines.

     Surface Mining Control and  Reclamation  Act of 1977 (30 CFR
700  et seq.).SMCRAsetsforththerequirementsandgeneral
performance  standards  for  surface mining activities throughout
the United States.  Under  the Act, mine  owners  are obligated to
restore  surface  mine  sites  to  conditions suitable  to support
vegetation  and  postmining  land  uses.   The  Act  specifies  that
nutrients and  soil amendments  should be  applied  to the surface
soil   layer   so  as  to   support   postmining  land  uses   and
requirements of revegetation.

     The Toxic  Substances  Control Act   (15  USC 2601  et  seq.).
The Toxic Substances Control Act (TSCA)  empowers  EPA to control
production and use  of  toxic substances.    Under the  Act,  EPA is
empowered  to regulate  any aspect of  chemical  use  likely  to
result in an unreasonable  risk of serious or widespread injury
to  public  health  or  the  environment.    The  Act  prohibits  the
production   of    polychlorinated    biphenyls    (PCBs)    after
January 1979  and  the  distribution  of  PCBs  in  commerce  after
July 1979, resulting  in an  expected  long-term decline  in  the
PCB content of municipal sludge.
                                20

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     The Act  also  requires coordination with the  CAA and Clean
Water  Act  to  restrict  disposal   of  hazardous  wastes.   High
concentrations  of  PCBs in  sewage  sludge would  cause it  to be
considered a hazardous waste regulated by TSCA.


Federal Requirements Relevant to EIS

     This  section  describes a  number of  federal  environmental
laws and  policies  relevant  to  EIS preparation.  Because  it is
not  presently  known  which specific  Metro  sludge  management
projects  EPA  may   be  funding,  compliance  with  many  of  the
requirements  cannot  yet be demonstrated.  EPA  will  comply with
such project-specific  requirements when and if  specific sludge
management projects are proposed for federal funding.

     National  Environmental Policy Act  (42  USC 4321  et seq.).
NEPA and regulations  issued pursuant  to  NEPA establish policies
and procedures  for  assuring that federal actions are consistent
with  the  nation's   environmental  quality   objectives.   NEPA
directs that,  to the fullest extent possible,  federal agencies
are to carry out their programs in accordance with NEPA policies
and procedures.  NEPA's "action-forcing mechanism" requires that
federal    agencies    prepare    EISs,    using   a   "systematic,
interdisciplinary  approach" to  assess  the  impacts  of  "major
federal actions significantly affecting the quality of the human
environment."

     Regulations of  the Council on Environmental  Quality (CEQ)
(40  CFR Sections  1500-1508)  and  EPA  (40 CFR  Part  6)  provide
detailed  requirements  for  implementing  NEPA.   Preparation  of
this   EIS   satisfies   EPA's   environmental   impact   review
responsibilities under NEPA.

     A-95  Review.   The Intergovernmental Cooperation  Act (ICA)
of 1968  (42 USC 4233)  and Office of Management  and Budget (OMB)
Circular  No.   A-95  (42  FR 4052,  January  13,  1976)  require
coordination  of federal aid programs with state,  areawide,  and
local comprehensive  planning.    The  ICA establishes  a national
policy  for intergovernmental coordination and  cooperation,  and
requires consistency  to the maximum extent  practicable  between
federal aid  for development purposes  and state,  regional,  and
local planning.

     OMB Circular A-95 establishes a system for notification and
review  of  state and  local applications for  federal  assistance
and  for   consultation   regarding   direct  federal  development
projects.  This A-95  review system also  provides  a mechanism
for dissemination of  EISs,  environmental assessments, and other
analyses prepared  by federal agencies  to interested  state  and
local government agencies  for  comments,  as  required by NEPA.
                               21

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Various  state   and  areawide  clearinghouses   facilitate  the
notification,  review  and  dissemination  of  project plans  and
EISs, as specified by OMB Circular A-95.

     This  EIS  will be  disseminated  through  the  A-95  review
system.   If  specific  Metro  sludge  management  projects  are
proposed  for  federal  funding,  Metro  grant applications  will
also be disseminated through the A-95 review system.

     Endangered  Species  Act  (16  USC 1536  et  seq.).   Federal
policiesandproceduresforprotectingendangered  and threat-
ened species of fish, wildlife,  and plants are established by
the  Endangered  Species Act (ESA)   and  regulations issued pursu-
ant  to  the  Act.   The purposes of  the Act  are  to provide mecha-
nisms for conservation of  endangered and  threatened species and
the  habitats upon which they  depend,  and to achieve  the goals
of international  treaties  and  conventions  related to endangered
species.   Under  the  Act,  the  Secretary  of  the  Interior  is
required to determine which  species are  endangered or threat-
ened, and to issue regulations for protection of those species.

     Section  7  of the Act requires  federal  agencies to consult
with the  U. S.  Fish and Wildlife Service  (USFWS)  in  order to
ensure  that actions  they authorize, fund, or carry  out are not
likely  to   jeopardize  the  continued  existence  of  a  listed
species or  result  in the adverse  modification  or destruction of
their  critical  habitat.   Upon determination that an endangered
or threatened  species  may  be  present in the area of a proposed
action,  the  responsible   agency  must  conduct  a  biological
assessment  to  identify  how  the   listed  species  might be  af-
fected.  The biological  assessment may be performed as part of
an environmental  assessment or EIS pursuant to  NEPA.   EPA will
undertake  Section 7 consultation  when  a  determination  is made
as to  which specific  Metro sludge management  projects  EPA may
be funding.

     The Coastal Zone Management Act  (16 USC 1451 et seq.).  The
Coastal  Zone Management  Act   (CZMA)  offers  grants to coastal
states  for  the  development  of  comprehensive, long range coastal
management  plans  meeting  broad   statutory  criteria,  and  for
state implementation of  these  plans following  federal approval.
The  Act is  administered  by the National Oceanic and Atmospheric
Administration  (NOAA).   In Washington,   the  approved  coastal
management  plan consists  of   the  state's Shoreline Management
Act  and local Shoreline Master Programs.

     The CZMA  (Section  307[d])  requires   that  federal  agencies
disapprove   funding  assistance  for  local  projects  that  are
inconsistent  with  a  state  coastal zone management  program.
State  coastal  management  agencies  are  required  to  make  the
consistency  determination  as  part  of  the  A-95 review of  the
application  for federal  assistance (15  CFR 930,  subpart F).  If
specific Metro  sludge  management  projects  affecting the coastal
zone are  proposed  for federal funding,  consistency determina-
tions for these projects  will  be made.
                               22

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     Cultural Resource Protection.  A number of federal laws and
regulations  have  been  promulgated  to  protect  the  nation's
historical, cultural, and  prehistoric  resources.   These include
the National  Historic Preservation  Act,  the  Archeological and
Historic  Preservation Act,   the  Archeological  Resources  Pro-
tection Act, and the American Indian Religious Freedom Act.

     Pursuant to the National Preservation Act (NPA)  (16 USC 470
et  seq.),   the  effects  of  any  federal  or  federally-assisted
undertaking on historical, cultural,  or archeological resources
must be evaluated.  An "effect" is  defined  as any change in the
quality of the characteristics  that  qualify the resource for
protection  under  the law  (36 CFR  800) .   For properties  on or
eligible  for the  National  Register  of  Historic  Places,  the
responsible federal agency must consult with  the  State Historic
Preservation  Officer  (SHPO)   regarding any  potential  adverse
effects on  resources  of  historic,  architectural,  archeological,
or cultural significance.

     The Archeological and Historic Preservation Act  (88  Stat.
174)  and  the Archeological  Resources  Protection Act  (93  Stat.
721)  safeguard  historical  and  archeological  resources   from
damage  or   loss  to federally-sponsored  or  permitted  projects,
and from  excavation or  removal  from federal and  Indian lands,
respectively.   The American  Indian Religious  Freedom Act (42
USC 1776)  assures  that federal activities  do not  impair access
to  religious sites  and  will not  affect  ceremonial  rites  of
American Indians.

     Cultural resource protection laws  will be  complied  with if
specific  Metro  sludge  management  projects  are  proposed  by
federal funding at sites where the resources could be affected.

     Recreational  and  Wilderness  Area Protection.  A  number of
federal  programs   have   been  created  to  protect   important
national  recreation  and  wilderness  resources.   These  include
the National Wild  and Scenic Rivers System,  established by the
Wild and Scenic  Rivers Act (16 USC  1271 et seq.);  the National
Trails  System,  established by the  National  Trails System Act
(16 USC 1241  et   seq.);  wilderness areas  administered by the
U. S.  Forest Service,  Bureau  of Land Management,  (BLM),  and the
National Park Service; Areas of Critical Environmental  Concern
administered  by   BLM;   and   estuarine  sanctuaries   designated
pursuant  to  the   CZMA.    In   general,  these  programs  include
provisions  to  discourage federal  agencies  from taking  actions
which would impair the  recognized values  of the resources in
question.    Recreational   and   wilderness  area  protection  laws
will  be  complied   with   if   specific  Metro  sludge  management
projects are proposed  for federal funding  at  sites where  these
resources could be affected.
                               23

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     Protection of  Agricultural Lands.   On September  8,  1978,
EPA  issueditspolicytoprotectenvironmentally  significant
agricultural  lands.    Under  this  policy,  EPA  is  required  to
identify  the  direct  and  indirect impacts  of  its  actions  on
environmentally significant  agricultural  lands and to  avoid or
mitigate, to the extent possible, identified adverse impacts.

     The Council on Environmental Quality issued a memorandum in
1980  emphasizing  the  need  for  determining  the  effects  of
proposed federal agency actions  on prime  or unique agricultural
lands  (45 FR  59189, September  8,  1980).   Prime farmlands are to
be considered a  "depletable  resource" and  impacts to  them must
be evaluated  in  the environmental  assessment  process.   Impacts
to be  evaluated  include reduction  in  farmland productivity and
conversion of farmlands to other uses.

     These  policies  will  be  complied with  if specific  Metro
sludge  management  projects  affecting agricultural  lands  are
proposed for federal funding.

     Floodplains and  Wetlands.   Executive  Order  11988  requires
federal  agencies,  in  carrying out  their  responsibilities,  to
take action t6 reduce  the  risk  of  flood  loss;  to minimize flood
impacts  on  human safety,  health,  and welfare;  and to restore
and  preserve  the  natural  and  beneficial  values  served  by
floodplains.  Executive  Order  11990  requires  federal  agencies,
in  carrying  out  their responsibilities,  to take  action  to
minimize  the  loss  or  degradation  of  wetlands, and  to  preserve
and  enhance  the  natural  and  beneficial  values  of  wetlands.
Each  agency  is  required  to   avoid   undertaking  or  providing
assistance for construction  in  wetlands unless the agency finds
there  is no  practicable  alternative and  the proposed  action
includes all practicable measures to minimize harm to wetlands.

     EPA  has  developed procedures  implementing  these  Executive
Orders  on  floodplain  management  and wetlands  protection  (40
CFR  6, Appendix A).  Under these procedures, EPA is  required to
assess floodplains and wetlands impacts  of its  actions,  and to
either avoid adverse impacts or  minimize  them  if no practicable
alternative to the action exists.

     These  policies  will  be  complied with  if specific  Metro
sludge management  projects  affecting floodplains and  wetlands
are proposed for federal funding.


State Requirements

     Solid Waste Management and Recycling (RCW 70.95).   This law
establishes  a  statewide  program  for solid   waste  management.
Sewage sludge is considered  a  solid waste,  and therefore sludge
management and disposal  must comply with provisions of the law
and  its  associated  regulations,   the  Minimum Functional  Stan-
dards  for Solid  Waste Handling  (WAC  173-301) .   Under  this law.
                               24

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each  county  board  of  health is  required to  adopt regulations
governing  solid  waste  handling and develop  a  permit system for
solid  waste  disposal  sites  or  facilities.   The  county regu-
lations  may  be  more  stringent than  the state's  minimum func-
tional  standards.   The law  also  requires preparation  of local
solid  waste  management plans,  which  must  address  sludge uti-
lization.

     The  state  has prepared draft  Municipal  Sludge Utilization
Guidelines  (Guidelines)   and  draft Best Management  Practices
(BMPs)  for Use of  Municipal  Sewage Sludge,  as  a  supplement to
the  state minimum  functional standards.  The  Guidelines estab-
lish  general  criteria  for the  storage,  transportation,  and use
of  municipal  sludge;   they  also  require  a  site  design  and
operation  plan  for sludge  utilization sites to be  approved by
the  jurisdictional  health  department.   The BMPs  provide techni-
cal  information  and  recommend  specific utilization  practices
complying with the  state Guidelines and federal criteria.

     Washington  Clean  Air  Act  (Chapter  70.94  RWC).   This  act
defines  public  air quality  policy,   delineates  air  pollution
control  authorities and   responsibilities  and  sets forth  the
framework  for  emission  control  schedules, variances, penalties,
burning permits, air pollution episodes, and outdoor burning.

     State  Clean   Water   Act   (CWA)   (RCW   90.48).    This  Act
establishes wastewater  discharge  standards  in  compliance  with
the  Federal  Clean  Water  Act;  these  standards  dictate  the
necessary  degree  of  treatment  which  in turn  influences  the
quantity  and quality of sludge.   Also, a proper  sludge disposal
plan  is  reviewed under the  NPDES permit process.   For  a given
sludge   utilization site,  the  Act  is  only   relevant  when
processing facilities  such as  digesters, dewatering equipment.,
drying  beds,  and  incinerators  are  involved;  when  there is  a
direct discharge  of pollutants  to surface water; or when sludge
is applied to  land  in quantities  above those  required  for crops
(Guidelines, Section 1.07).

     Washington  State  Environmental   Policy  Act  (RCW  43.21C).
This  Act and its  implementing  guidelines (WAC  197-10)  require
that   environmental factors   be  included   in   state   agency,
municipal  and public  corporation,  and  county  decision-making
processes.   The  Act  requires  state   EISs  to be  prepared  for
actions  significantly affecting the quality  of the environment.
Under  the  SEPA  guidelines  (WAC  197-10-650),   adequate  EISs
prepared  under NEPA may be utilized by state and local agencies
in lieu  of a  separately prepared EIS  under  SEPA;  Metro intends
to use this EIS to  satisfy SEPA requirements.

     Shoreline  Management  Act   (RCW   90.58.200).   This  Act,
together  with  local  Shoreline  Management  Programs  prepared
pursuant  to  state  guidelines   (WAC  173-16),  comprise  Wash-
ington's  coastal   zone  management  program.   Local  Shoreline
Management Programs cover  shorelines  of marine  waters,  lakes
                               25

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over  20  acres,  and  streams  with  flows greater  than  20  cfs.
Each  Shoreline  Management Program  must reflect  state policies
for  four  types  of environments  (natural,   conservancy,  rural,
and  urban),  state-designated  shorelines of  statewide signifi-
cance,  a  number  of   natural   systems,   and  a  number  of  use
activities (which  include  forest management  practices and solid
waste  disposal).   Metro's sludge  disposal   siting  must  conform
with local Shoreline Management Program requirements.

     Forest Practices  Act  (RCW 76.09).  This Act and the associ-
ated  ForestPracticesRegulations(WAC 222-08  et  seq.)  estab-
lish  minimum  standards   for   forest  practices  in  Washington.
Silvicultural  application o.f  wastewater  sludge will need  to
comply with  relevant  forest practices standards  and administra-
tive procedures.


Local Requirements

     Specific sludge management projects implemented pursuant to
Metro's Sludge  Management Plan  must  comply  with a  variety  of
local  requirements, including  jurisdictional  health department
regulations,  local solid waste 'management plans,  and local land
use  and   Shoreline Management  Plans  and  policies.   Jurisdic-
tional health  departments are  required by  state law to  issue
permits  for  sludge  utilization  projects  on land,  and  local
agencies may also  require  grading permits,  special  use permits,
or  shoreline  permits,  depending  on  the  local  jurisdiction.
Jurisdictional health department  levels of  review and forms  of
approval  for a  given sludge  utilization  project   are  at  the
discretion of the health  department (Guidelines,  Section  1.04).

     Snohomish County's  requirements  are particularly  relevant
to  Metro's   Sludge  Management  Plan  because  the Pilchuck  Tree
Farm  Demonstration Project,  proposed as  part of Metro's  plan,
is  located in  Snohomish  County-   The Snohomish  Health District
requires a permit for land  application of  wastewater  sludges.
Criteria  for approval are based on  compliance  with  the  state
Guidelines and federal regulations.
                               26

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	Chapter 2
 Description of Sludge Management Alternatives
                                           •Overview
           •Metro's Existing Sludge Management Concepts
                  •Existing Sludge Management Methods
                   •Description of Alternatives Considered
 •Metro's Preferred Long-Range Sludge Management Program
                       •Metro's Preferred Near-Term Plan

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                            Chapter 2
          DESCRIPTION OF SLUDGE MANAGEMENT ALTERNATIVES
     This  chapter  presents  an  overview  of  sludge  management
methods,  describes  Metro's  existing sludge  management methods
and existing sludge characteristics, and describes future sludge
management alternatives considered and recommended by Metro.


             Overview of Sludge Management Concepts


Sludge Management Principles

     Sewage sludge  is the  semi-solid material formed during the
wastewater  treatment  process.   It  consists  of  organic  and
inorganic  solids  removed  during  primary treatment  and organic
solids  removed   during   secondary   treatment.   Sewage  sludge
typically  undergoes treatment  prior  to disposal  or  reuse  to
achieve volume reduction and disinfection.  Following treatment,
it is transported to a disposal or reuse site.

     The  sludge treatment  process is designed to  transform raw
sludge  into a  more manageable  form.   Depending  on  the  final
usage,   sludge   may   be   thickened,   digested,   conditioned,
dewatered,  composted,  dried,  disinfected,  and/or  incinerated.
Thickening  increases  the  solids  concentration,  reducing  the
volume.   Digestion  stabilizes  the  sludge,  reduces  its volatile
solids content, and provides some disinfection.  Also, energy in
the  form  of methane  gas  can  be  recovered  using  the anaerobic
method of  digestion.  Conditioning  serves  to improve the sludge
dewatering  and   may  be   a   chemical  or  physical  technique.
Dewatering  increases  sludge  solids  content  and reduces volume,
by  removing a  significant  portion  of  the  water  contained  in
sludge and  some dissolved  constituents  such as ammonia-nitrogen
and potassium.  Composting oxidizes part of the  organic matter
in  sludge and can  result in  a  drier,  less  odorous,  and  more
disinfected product.  Sludge disinfection  removes  pathogens and
prevents the spread of diseases.   Drying further reduces sludge
moisture  content  and  volume.   Incineration  greatly  reduces
sludge mass and volume and results in a sterile ash for disposal
(EPA 1979a).

     After  treatment,  sludge  must  be  transported  from  the
treatment  plant  to a  disposal or   reuse  site.   Transportation
also may be required between the raw sludge collection point and
the sludge  treatment  site.  Common  modes  of  transport  are via
truck, pipeline, barge,  and train.
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     The final disposition of sewage sludge can include disposal
or some  beneficial  usage.  Landfilling  (a  disposal method) has
been commonly  used  in  the  United States.  Marine  disposal has
been essentially  eliminated as  a disposal system  by action of
the  Marine  Protection,  Research  and  Sanctuaries  Act.   Soil
reclamation,  urban  marketing,   agricultural  land   application
(food  chain crops), and  forestland application  (nonfood  chain
crops), are examples of beneficial reuse of sludge.


Sludge Management Approaches of United States Cities

     The main methods  for sludge disposal throughout the United
States in 1982 were:

     o  Incineration
     o  Landfill disposal
     o  Land spreading  (food chain or nonfood chain)
     o  Distribution   and  marketing   as  fertilizer  and  soil
        amendment
     o  Ocean dumping  (which is being phased out)

     A  survey  of  350  large  publicly-owned  treatment  works
(accounting for about  40  percent of the  sludge produced in the
United  States)   provided   the  disposal  distribution shown  in
Figure 2-1  (Peter  i_n Bledsoe 1981) .  With  phasing  out of ocean
dumping,  those  percentages will  change  as alternative  methods
are employed.  Some  examples of  sludge management programs used
by cities throughout the United States are discussed below.

     Chicago, Illinois.   During  the past 10  years,  the  Chicago
Metropolitan  Sanitary   District   sludge  management   program has
consisted of reusing heat-dried,  air-dried  and  liquid sludge to
reclaim  approximately   40,000  acres  of  strip-mined  land,  as  a
soil amendment for citrus farms in Florida, as compost, and as a
top dressing for landfill sites.   The  District  produces  450 dry
tons of  sludge  per  day,  and presently almost all  is  used  as  a
top  dressing   for   the  City   of  Chicago  landfill   or  for
horticultural application  (Gschwin pers. comm.).   Future plans
include using sludge  for  growing nursery stock on  a City-owned
site north  of Chicago.  The  soil reclamation  program and citrus
farm programs have been phased out for economic reasons,  and the
composting  (NuEarth soil supplement)  program has been phased out
because of  concerns related to  heavy metals concentrations  in
the sludge  (Gschwin pers.  comm.).

     Denver, Colorado.   Denver uses a land application method as
its primary means of disposal;  landfilling is used as a backup
during cold weather  (EPA 1979a).   Land application,  employed
since 1969,  consists of sludge application to the  land, plowing,
and sowing  with  a  forage  crop  2 months  following  application.
Cattle then graze  the area  (Kienholz  in  Energy  Research and
Development  Administration  1976) .   During  cold  weather  this
process cannot occur and a landfilling procedure is implemented.
Sewage sludge is mixed  with about 5 or 6 parts  of soil and then
layered on top of low areas in a  landfill.


                                28

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                     Distribution
               Non-\     and
               Food-\  Marketing
               Chain
                  3%
           Food - Chain
           Application
             16%
THIS DIAGRAM IS COMPILED FROM DATA FROM ABOUT 350 LARGER PUBLICLY
OWNED TREATMENT WORKS (POTWs) ACROSS THE UNITED STATES.
                             SOURCE: PETER IN BLEDSOE, 1981
                    FIGURE 2-1
        The Distribution  of  Sludge
 According  to  the  Method  of Disposal
                         29

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     Milwaukee, Wisconsin.   Milwaukee  has  recycled  its  sewage
sludge as a soil  conditioner  since  1926.   Approximately 190 dry
tons per day are heat-dried and packaged for marketing under the
trade name of Milorganite.

     Los  Angeles  and  Orange   Counties,   California.   Sludge
management for  this  metropolitan area  is shared  by three agen-
cies:  the City of  Los  Angeles, the Los Angeles  County Sanita-
tion Districts, and  Orange County Sanitation  District.  A joint
management plan has been developed which calls for a combination
of  thermal processing with energy recovery,  composting for use
as  a  soil amendment, and  landfilling.   Currently, the  City of
Los Angeles discharges  sludge to the  Pacific  Ocean; in 1978, it
disposed of approximately  164 dry tons  per  day via the outfall.
The  Los  Angeles  County  Sanitation  Districts  windrow-composts
about 1,000 wet tons per  day,  about  half of  which  is  used as a
soil  amendment.   The remaining  compost is landfilled.   Orange
County Sanitation District currently disposes  of its sludge at a
landfill.
Sludge Management in Washington Cities Outside Metro Boundaries

     City of Arlington.  Approximately  1,500  gallons  per day of
liquid primary  and  secondary sludge are  landspread  adjacent to
the  Arlington  airport.    The   700-acre   site  has  an  expected
lifespan of 15 years (Schlagel pers. comm.).

     City of  Tacoma.   Sludge  from the  City  of  Tacoma's  three
primary  treatment  plants  is  anaerobically  digested  and  then
landspread.   Total sludge volume is approximately 85,000 gallons
per  day,  with  the  main treatment  plant,  contributing  45,000-
50,000 gallons,  having  a solids content  of 5-6  percent.  Land-
spreading projects have included sod farming,  a topsoil product,
and  fertilization  on   local  lands.   Future  projects  planned
include forest  fertilization for harvest of  trees  as  firewood,
and  digester  gas  recycling  as  fuel  for city  vehicles (Price
pers. comm.).

     City of  Edmonds.   The sludge  from  Edmonds1  primary treat-
ment facility plant, which serves a population  about  45,500, is
incinerated and  the ash landfilled.  The incineration produces
about 25-30 cubic yards of ash per year  (Kopan pers. comm.).

     City of  Olympia.    Olympia has  a  15-year   agreement  with
WIDCO to provide 6.5 dry tons of sludge at 16  percent solids per
day.   The sludge  will  be  used  as   a  part of WIDCO's  soil
reclamation program (Kolby pers. comm.).

     City  of  Everett.   The  Everett  treatment   plant  provides
secondary treatment with aeration lagoons.  The lagoons have not
been dredged  in the past, and therefore a sludge disposal method
                              30

-------
has not been necessary.  The  City  is  planning a lagoon dredging
project  followed  by  landspreading  on city-owned  land (Olivers
pers. comm.).

     City  of  Bremerton.   Bremerton  has  two  primary  treatment
plants  serving  a  population of  approximately  35,000.   Sewage
sludge is  anaerobically digested and  then applied to forestland
as  a fertilizer.   Approximately  1,500  gallons  of sludge  are
applied  per  day  to  320   acres   of   forestland owned  by  the
McCormick Land Company (Proctor pers.  comm.).

     City  of  Lynnwood.  The  City  of Lynnwood  provides  primary
treatment  for  about  26,000  people.   The  sludge  collected  is
incinerated and the ash is landfilled.
           Metro's Existing Sludge Management Methods


Introduction

     The  following  sections  of  the  EIS  describe  the  basic
features  of  Metro's  existing  sludge  treatment  and  -handling
methods.   A  more  detailed  discussion  of  Metro's  wastewater
treatment  and sludge  management systems appears  in the  Draft
Sludge Management Plan and Technical Memorandum No. 1 of Metro's
Draft Wastewater  Management  Plan for the Lake Washington/Green
River Basins  (1979a).


Sludge Treatment

     Existing.   Sludge  is  generated  at all  five  of  Metro's
treatment plants:   Renton,  West Point,  Alki,  Carkeek Park,  and
Richmond  Beach.   Sludge management  is  centralized at  the  West
Point Treatment Plant.

     Sludge generated  at the Renton  Treatment  Plant  as  a result
of  primary treatment   (sedimentation)   and  secondary  treatment
(activated  sludge)  is transported to  the West  Point  Treatment
Plant via a  combination sewage/sludge  force main  (Elliott  Bay
Interceptor)  (Figure  2-2) .  Digested  sludge  generated at  the
Alki, Carkeek, and Richmond Beach Treatment  Plants, all  of which
are  primary  treatment  plants,   is  either trucked  to   the  West
Point plant or to  the  Interbay Pumping  Station for transfer via
the   Elliott   Bay   Interceptor   to  the   West  Point   plant
(Figure 2-2).

     All  sludge generated  at the West Point Treatment  Plant or
received  there   from   the  four  other  treatment  plants   is
anaerobically  digested  and  dewatered  to  18  percent  solids.
Figure  2-3  presents a  flow  diagram  of Metro's  existing sludge
treatment and disposal facilities.
                               31

-------
          RICHMOND BEACH
          TREATMENT
          PLANT
           CARKEEK PARK
           TREATMENT
           PLANT
WEST POINT
TREATMENT
PLANT
                                 RENTON
                                 TREATMENT
                                 PLANT
                                       SOURCE: METRO,1983a
                 FIGURE 2-2
Metro's Wastewater Treatment  Plants
     and Sludge Transfer Facilities
                      32

-------


RICHMOND
BEACH

CARKEEK
PARK

RENTON

WEST
POINT

ALKI


primary N

sludge '
primary s
I
sludge x

Anaerobic
Digestion

Anaerobic
Digestion
sludge

digester gas v

sludge
s^ digester gas v




secondary
sludges

X1


\x\x\
\ /
I
primary \
sludge '

/ \ Primary
^ / Settling
^
)
sludge
Anaerobic
Digestion


digester gas v



v Anaerobic
' Diaestion , \ ,- , •
'aci" j Composting

v N x
. . / Duwaterinu •——} Truck "/ WIDCO
sludge ' * s '

centrate
~? Cedar Hills

/\
digester gas v


                 FIGURE 2-3
               Flow Diagram of
Metro's Sludge  Treatment and Disposal Processes

-------
     Sludge treatment  and  handling at the  West  Point Treatment
Plant consists of conventional  anaerobic  digestion to stabilize
the  sludge and  reduce the  quantity of  volatile  solids.   The
sludge  is  dewatered  to  18  percent  solids  using centrifuges.
Dewatered sludge is transferred to 30-cubic-yard capacity trucks
via. a hopper loader system.  Sludge is then trucked to the reuse
or disposal sites.

     Scheduled.   Metro's  Draft Wastewater  Management  Plan  for
the  Lake  Washington/Green River  Basins  and  EPA's accompanying
EIS  (1980)  discussed  and  analyzed  the  addition  of  sludge
handling facilities  at the Renton Treatment  Plant.   Since that
time  predesign  studies  have   been  completed,  and  facilities
design  is  scheduled  to begin in January  1983 with construction
scheduled  to  begin in  the summer of  1984.  The  Renton sludge
handling facilities will  include  four  anaerobic  digesters, four
thickeners, one blending digester and four belt presses designed
to provide 20  percent  solids  (Hammond  pers. comm.).  Once these
facilities are  completed   (approximately  1987) ,  all  sludge from
the  Renton Treatment Plant will  be  handled  onsite,  and sludge
transport to West Point will be eliminated.


Present Sludge Transport and Reuse Methods

     After sludge is anaerobically digested and dewatered at the
West Point  Treatment  Plant,  it is transferred  to 30-cubic-yard
capacity  trucks  for  transfer  to  existing  sludge  management
sites.   Approximately  nine   truckloads  of  sludge   (250  cubic
yards)  per  day are transported from West  Point  to one  of five
reuse sites mapped in Figure 2-4:

     o  King County's Cedar Hills Regional Landfill
     o  Washington  Irrigation   and  Development  Company  (WIDCO)
        strip mines near Centralia, Washington
     o  Sawdust Supply Company  (GroCo,  Inc.) in Kent,  Washington
     o  Duvall Landfill
     o  University  of  Washington's  C.  L.  Pack  Forest,  Eaton-
        ville, Washington

To  date,   the  capacities  of  those disposal sites  have  been
adequate to  accommodate all  sludge produced  at  Metro treatment
plants.

     Cedar Hills  Regional Landfill.   The  Cedar  Hills  landfill
has  been  used  as  a sludge  reuse site  since 1973.  Sludge  is
transported by  trucks  from the West Point Treatment Plant  and
unloaded into  holding  ponds at the  landfill site.   During  the
summer  months,  King County personnel  mix  the sludge with sand
and apply  the mixture  as  a top  dressing  to  assist in establish-
ment  of  vegetation  for  erosion  control.   Approximately  49
percent (5,652-6,653 dry  tons  per year)  of sludge generated  by
Metro's wastewater treatment plants during  the past 3 years  has
been applied to the landfill (Metro 1983a).
                              34

-------
C L. A L L A M
              j.    Olympio.  '->_
                                   SKA 6 I T
                                   fj(.rlinaiien


                                     N 0 H O M I S H
                                      'DUVALL
                                       LANDFILL
                                     K  /
                                     • CEDAR HILLS
                                      LANDFILL
                                  GROCO
                              Eaton vil/e.            \

                               *PACK FORESTv
                                                 >
                                                 'v-<
                   FIGURE 2-4
         Existing Sites  for Reuse of
                 Metro Sludge
                       35

-------
     WIDCO.  The  WIDCO operates  a  22,000-acre coal  strip mine
within  Lewis  and  Thurston  Counties.   To date,  approximately
3,300 acres  have  been mined  and reclaimed.   Approximately 250
acres of land are surface-mined annually.

     Since  1978,  Metro has  been transporting sludge  from the
West Point  plant  to storage lagoons  located  on WIDCO property.
Metro was  under  contract  with WIDCO  to supply 22,000  wet tons
(approximately 3,800 dry tons)  of sludge to the site during 1982
(Metro/WIDCO Agreement,  February 1982) .   WIDCO  is  responsible
for  all  on-site  activities  including  sludge storage,  sludge
application, and  monitoring.   Approximately  32 percent  of the
sludge  generated  by Metro's wastewater  treatment plants during
the past 3 years has been transported to WIDCO.

     GroCo,  Inc.    Since  1976,  Metro  has supplied  sludge  to
GroCo,  Inc., a subsidiary  of  Sawdust  Supply Company  of Kent,
Washington,  for  purposes of  composting  and  distribution  as  a
soil conditioner.   GroCo,  Inc. owns  a  12-acre site  in  a heavy
industrial area of North Kent.   Sludge is mixed with sawdust (at
a ratio of 3 parts sawdust to 1 part sludge) and placed into 50-
foot-high   "static"   piles.   The   sludge  is   composted  for
approximately  6  months  and then  sold  to  public agencies and
private  landscaping firms  for  $7.00  to  $9.50  per  cubic yard
(Moss pers.  comm.).

     Metro was under contract  with  GroCo,  Inc. to transport and
deliver 15,000 wet tons (3,000 dry tons at 20 percent solids) of
dewatered,  digested sludge to  GroCo during  1982 (Metro/GroCo,
Inc.  Agreement,  March  1982).   GroCo,  Inc.  is responsible for
providing  storage  space  for the  sludge  and assuring protection
of public health and safety at the composting site.

     Duvall  Landfill.   During  1982  Metro began  a  program of
supplyingsludgeto the Duvall  sanitary landfill for  the pur-
poses  of  soil improvement  as  a landfill  cover.   The  sludge
supplied  to  the  Duvall landfill during  1982  represented  only a
small part of Metro's annual sludge production.

     Pack  Forest.   Metro  has  been   supplying  sludge   to  the
University of Washington's. Pack Forest in Eatonville since  1974.
The  sludge has been used for a variety of silvicultural research
programs  at  the  forest and  also  at  Pope and Talbot Company land
near  Port   Gamble,  Washington.    The  silvicultural  research
studies  have  generated  a  significant  amount of  data  on the
response  of trees  to  sludge  application  and  have   led  to
publication  of a series  of University  of  Washington bulletins
entitled  Use of  Dewatered  Sludge  as  an  Amendment  for  Forest
Growth.

     During  1982, Metro transported and delivered  55 wet  tons of
sludge  to  storage  lagoons  at  the  Pack  Forest.   Since  1979,
approximately  10  percent  of Metro  sludge has  been  utilized on
120  acres of forest lands.
                               36

-------
Past Sludge Disposal and Reuse Methods

     From '1966  to  1972,  Metro disposed  of digested  sludge by
discharge  through the  West  Point  effluent outfall  into Puget
Sound.   Ocean  disposal was  discontinued  in  1972  because  of
federal  and  state  policies  discouraging  ocean  disposal  of
sludge.  A  sludge lagoon at the West  Point Treatment Plant was
used  for  sludge  storage  following  discontinuation  of  sludge
disposal to Puget Sound in 1972.

     In  the  early- and  mid-1970s,  Metro  began a  series  of
demonstration and soil improvement projects  throughout Seattle
with  the  cooperation  of  the  University  of  Washington  and
Washington State  University.   Table 2-1  indicates the locations
and  dates  of  those  past  projects.   One  outcome  of  those
demonstration   projects   was   a  number   of   research  reports
pertaining   to    public   health  issues,   impacts   of   sludge
application  on  wildlife,  sludge   composting,  and  results  of
applying sludge to forest and agricultural land.


Pretreatment and  Source Control

     One important component of Metro's wastewater treatment and
sludge  management  programs  is  the  pretreatment  and  source
control  program.    The purpose  of  the  program  is  to  require
industrial dischargers  to meet  certain limits  for the discharge
of  toxicants  and heavy  metals  into Metro's wastewater  system.
Metro has  established  discharge  limitations that  must be met by.
industries.   Industries therefore  have  installed  pretreatment
processes  to  reduce the  quantities  of metals  and other pollu-
tants prior to discharge into the Metro system.  Metro presently
conducts an  intensive  discharge  sampling  and monitoring program
to ensure compliance with established limits.

     Metro's pretreatment  and  source control  program  is impor-
tant to sludge management because a majority of the heavy metals
(70-90 percent)  discharged from industries into the Metro system
are  removed  from  effluent  during  wastewater  treatment  and
transferred to  Metro  sludge.   Therefore,   if greater  amounts of
heavy metals  can  be removed from industrial effluents  prior to
discharge to Metro's system, the concentrations of trace metals
in Metro's  sludge will be reduced as well,  thus  increasing the
feasibility of beneficial sludge reuse.

     A more detailed  description  of  Metro's  pretreatment  and
source control program appears in Metro's NPDES Special Study of
Heavy  Metal Loads  in  Renton  and  West  Point  Treatment  Plants
(1979b).    Also,  Metro has  initiated  a   Toxicant  Pretreatment
Planning Study  (TPPS),  designed to identify sources of toxicants
within  Metro's   wastewater  collection   system.    Preliminary
results  of  the  study  have  been   included in Metro's  Sludge
Management Plan  (1983a);  however,  the project  is  not scheduled
for completion until mid-1983 (Hilderbrand pers. comm.).
                               37

-------
                              Table 2-1.  Metro's Past Sludge Disposal  and Demonstration  Programs
        Project Name
                                             Date
                          Purpose
U)
oo
Puget Sound Outfall
Cedar Hills Landfill
Midway Landfill
Duvall Landfill
Gas Works Park
Myrtle Edwards Park
Boeing Air Field
WIDCO coal mine

Grouse Ridge Gravel Pit
South Seattle Community College
West Point Sludge Lagoon
University of Washington Pack Forest

Pope and Talbot

Pilchuck Tree Farm Christinas Trees
1966-1972
1973-present
1981
1982-present
1974
1975
1979-present
1978-present

1978-1979
1930
1968-1981
1974-present

1973

1980-
        Washington State University Field Stations   1975
        GroCo Compost
                                             1976-present
Disposal
Soil improvement-landfill cover
Soil inprovement-landfill cover
Soil iirprovement-landfill cover
Soil improvement-park development
Soil improvement-park development
Soil improvement-turf enhancement
Soil inprovement-Centralia strip mine
 restoration
Soil improvement-gravel pit restoration
Soil improvement-arboretum development
Beachfront earth fill  (lagoon removed, 1981)
Forest land application - University
 research forest near Eatonville
Forest land application - Douglas fir
 stands near Port Gamble
Forest land application - Christmas tree
 plantation near Arlington
Agricultural application - field research
 stations at Mt. Vernon, Kent and Puyallup
Composted sludge/sawdust product
        SOURCE:   Metro 1983a.

-------
              Existing Metro Sludge Characteristics


Sludge Quantities

     Table 2-2 indicates the quantities of sludge produced daily
and annually at the West Point  facility  from 1978 through 1982.
As previously mentioned, all sludge generated at Metro treatment
plants is processed  at  the West Point plant.   Figure 2-5 shows
the amounts  of sludge  sent to  the West  Point plant  from  the
Renton plant  for the  period January  1978 through  March 1980.
Renton Treatment Plant  sludge makes up approximately 40 percent
of the  influent  suspended solids  to the West  Point plant (EPA
1980a).

     As indicated in Figures 2-5 and 2-6, there is a substantial
seasonal variation in sludge production.   Several factors appear
to cause  the  seasonal  differences:   1)  solids  accumulated  in
interceptor systems during the dry summer months are flushed out
during  the  wet  season, 2)  more  solids  are  brought  into  the
combined  sewage/storm  system  during  the  wet months,   and  3)
solids have  been found  to settle  out more readily  during  the
winter months  (Metro  1983a;  Uchida pers.  comm.).   The seasonal
change in  sludge  production affects the  sludge transportation,
storage and distribution needs.

     Sludge production is projected to increase substantially by
the year  2000.   Figure 2-7  depicts  the  quantities  of  sludge
projected to be generated  by Metro by  the  year 2000, assuming a
2.6 percent  annual  increase in sludge volume  from 1985 through
2000  (Metro  1983a).   This assumed  increase  is  based on:   1)
projected  population growth  within the  service  area and,  2)
secondary wastewater treatment at the Renton Treatment Plant and
continued primary  treatment  at  the West Point Treatment  Plant.
Any changes in expected population growth and discharge require-
ments would affect the projected future sludge quantities.


Sludge Quality

     Monitoring  of  sludge  quality parameters such  as  trace
metals (e.g., cadmium, chromium, lead), pH, nutrients  (nitrogen,
potassium, and phosphorous), trace  organics  (e.g.,  PCBs,  DDT)
and pathogens is important to determine the allowable methods of
sludge reuse or disposal.

     During  1981,  Metro began  an  intensive program  to monitor
the physical,  chemical,  and  microbial  characteristics of sludge
from the Renton and West Point Treatment Plants.  The monitoring
program was carried out from May 27 to September 2, 1981 and was
designed  to  provide  Metro  with   an  accurate  analysis  of  the
sludge and an understanding of the variability of sludge quality
over  time.   A list  of  the sludge monitoring  parameters  is
presented in Appendix B  of this EIS.   A  detailed description of
                               39

-------
                    Table 2-2.  Metro Sludge Quantities
                                 1978-1982
Units/Year                1978      1979      1980       1981       1982
Dry tons of digested
 sludge per day
 (annual average)         20.2      27.9      31.6       37.2       35.1

Percent increase over
 previous year                      38.2      13.1       17.7       <4.7>]

Wet cubic yards of
 digested sludge per
 day  (annual average)     142.6     197.8     210.0      247.6      256.9

Number of truck loads
 per day  (30 cu. yd.
 capacity)                    57789

Total dry tons of
 digested sludge          7,300    10,200    11,540    13,585      6,4125


NOTES:  x< > indicates a decrease.
        2Six-month period only  (January through June).
SOURCE:  Metro 1983a.
                                     40

-------
to
o
o
Q-
O
O
o

I
o
UJ
Q.
a.

UJ
«>
o
200-


(80-


160-


140-


120


100-


 80


 60


 40


 20


 0
                     Raw Sludge
Waste Activated Sludge
          IIIIIIIIIIIIIIIIIIIIIITI   I  I  I   I  I

          JFMAMJJASONDJFMAMJJASONOJFM   A  M   J
                     1978
                                             1979
                                                   1980
                                                                    SOURCE: METRO.1980a
                                FIGURE 2- 5

            Pounds of  Sludge Pumped to  West Point

-------
1500
   JFMAMJJASONDJFMAMJJASOND
                                         SOURCE: METRO.1983a
                   FIGURE 2-6
               Monthly Variation
        in Metro's Sludge Production
                      42

-------
LJ
            80-1
            70-
            60-
         to >< 50
         0) M
          a)
            40-
         m ,
         u.
         Q
            20-
             10-
             0

              1980
1985
1990
1995
2000
                                               -550



                                               - 500



                                               — 450

                                                   •a
                                                   a>
                                               — 400 •£
                                                   0)
                                                   ra

                                               - 350 Qj

                                                   oc

                                               — 300 ^ i



                                               - 250 o


                                               - 200 o

                                                   4—'

                                               - 150 $


                                               — 100



                                               -50
                                                                                CD
                                     FIGURE  2-7
                                                                      SOURCE: METRO. 1983 a
                      Summary of Future Sludge  Quantity
                  (Dry Tons  and  Wet Cubic Yards per Day)

-------
Metro's  sludge  monitoring  program  appears  as  an  appendix  to
Metro's Sludge Management Plan (1983c).  Table  2-3  presents the
results of the May 1981 to May 1982 sampling conducted by Metro.

     Trace  Metals.   As  previously   mentioned,   trace  metals
(e.g., lead,  zinc, cadmium,  arsenic,  chromium,  copper, mercury,
and  nickel)   are  one   component   of  municipal  and  industrial
wastewater  sludge.   These  metals come  from sources  including
industrial contributions, urban storm  runoff  and  from corrosion
of water distribution and wastewater collection systems.

     The concentrations  of  trace  metals measured  in sludge are
one characteristic for  determining whether sludge is classified
as  a  hazardous  waste  or  a  solid  waste  according  to  EPA
regulations  (40 CFR,  Parts  260-265).   Metro  sludge has  been
tested and is classified as a solid waste  (cadmium concentration
of 46 mg/kg in  Metro's  sludge  is  well  below  the mg/kg EPA limit
which would establish sludge as a hazardous waste).

     Data  from  Metro's  sludge   monitoring  indicate  that  the
concentrations  of  trace  metals   in  raw primary  sludge at  the
Renton  facility are somewhat  lower  than  those in  raw  primary
sludge  from  the  West  Point  Plant.   However,   the West  Point
values are  a  blend of Renton  sludge  (raw  primary  and raw waste
activated)  and  West  Point raw primary sludge so  that  the  metal
concentrations  of  sludge  at West Point  alone are  not presently
known.

     In general, the concentrations of metals in Metro digested,
dewatered  sludge  are  comparable  to  those  of  the  City  of
Portland, Oregon  (EPA  1979b),  and for  other  major cities in the
United States (EPA 1979a).

     Nutrients.   Nutrients typically occurring in sludge include
nitrogen (organic and  ammonium),  phosphorous  and  potassium.  It
is because of these nutrients that EPA policy has encouraged the
beneficial reuse of  sludge  by  land spreading (soil reclamation,
silviculture  or agriculture)  or   composting.   Prior  to  sludge
digestion,  nitrogen  is  mainly  found  in the form  of ammonia and
organic nitrogen.  Digestion increases the ammonia concentration
due  to  partial decomposition  of organic nitrogen.   However,
dewatering removes a substantial amount of the ammonia.

     Trace Organics.   Trace organics include toxic substances as
pesticides  and  herbicides  (chlordane,   DDT,  endrin)  and  PCBs.
Metro  has  a  program  of monitoring  trace  organics.   Table  2-3
indicates  that  although  many  of  the  organics  are  tested,
concentrations  of  all  but PCBs have been  undetectable  in  Metro
sludge.

     Pathogens.   Bacteria, viruses,  and  parasites are typically
found  in  sludge.   In  order  for   sludge  to be  applied  to  land,
it must be subjected to a process which, as defined by EPA, will
"significantly   reduce   pathogens"    (40   CFR,    Part   257)  .
                              44

-------
                     Table 2-3.  Existing Sludge Physical,  Chemical,  and Microbial Quality
                                       (Mean Values, May 1981 - May 1982)

Flow - metric tons (dry wt. ) per day
Total solids (percent of wet wt.)
pH
Nutrients (percent of dry wt.)
Organic - N
Ammonium - N
Total - P
Total - K
Trace metals (ing/kg)
Arsenic
Cadmium
Chromium
Copper
Lead
Marcury
Nickel
Zinc
Trace organics (mg/kg)
PCBs
Chlordane
Dieldrin
DDT
Aldrin
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP (Silvex)
Bacteria (geometric mean; n = 12-16)
Total coliform (mpn/lOOg wet)
Fecal coliform (mpn/lOOg wet)
Fecal streptococcus (mpn/lOOg wet)
Salmonella (mpn/lOOg wet)
Shigella (mpn/lOOg wet)
Yersinia (mpn/lOOg wet)
Virus (geometric mean; n = 11)
Total virus (pfu/lOOg wet)
Parasites (no. of positive
identifications )
Giardia
Coccidia
Ascaris
Vfest
Raw Primary
72.2
5.7%
5.3

4.5%
0.28%
1.06%
0.18%

6.7
25.0
240.0
730.0
420.0
3.3
110.0
1,080.0

1.4
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*

.38E10*
.16.E9
.58E8
.33E3
<.3E2~
.20E4

100.0

1/16 samples
2/16 samples
0/16 samples
Point
Digested ,
Dewatered
36.5
18.4%
7.4

3.4%
0.9%
1.5%
0.15%

14.0
46.0
390.0
1,160.0
720.0
6.2
155.0
1,730.0

1.6
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*

.23E9
.20E8
.33E8
.95E2
<.3E2
.15E4

8.0

1/16 samples
4/16 samples
3/16 samples

Raw Primary
23.8
1.05%
6.4

4.10%
0.25%
1.12%
0.48%

4.4
10.2
154.0
420.0
185.0
2.80
56.0
666.0

0.6
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*

.19E10
. .13E9
.22E8
.65E2
<.3E2
.58E3

101.0

2/10 samples
1/10 samples
0/10 samples
Renton
Raw Waste
Activated
16.1
0.33%
7.1

8.26%
0.51%
2.86%
0.90%

6.4
19.4
287.0
997.0
280.0
3.1
91.0
644.0

0.5
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*

.30E9
.24E8
.76E7
.60E2
<.3E2
.36E3

30.0

1/10 samples
0/10 samples
0/10 samples
SOURCE:  Metro 1983a.

* E = Exponential base 10.
                                                      45

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Anaerobic digestion  is  a  process which can  reduce  pathogens by
95-99 percent.   Table 2-3  identifies  the results  of bacteria,
virus,  and  parasite  monitoring at  the West  Point  and  Renton
treatment plants.  A detailed analysis of the pathogens normally
found in  sludge  can be found in Appendix  A of this  EIS  and in
Metro's Sludge Intensive Monitoring Report (1983c).

     Future Sludge  Quality.  The future quality of  Metro sludge
will rest on a number of factors:

     o  Potential changes in industrial pretreatment standards.
     o  The  possibility  of  separating  industrial  wastewater
        flows from municipal flows.
     o  Success  of  the  City of Seattle Water  Department's pipe
        corrosion control program.
     o  Changes  in   sludge  processing  at   Metro's  treatment
        plants.

     Such changes could provide  Metro  sludge with lower concen-
trations of trace metals which,  in turn, would allow for greater
flexibility in sludge management programs.


         Description of Alternatives Considered by Metro


Introduction

     As  part  of  the Wastewater Management  Plan  for the  Lake
Washington/Green  River  Basins,  Metro  initiated  an  analysis of
sludge  disposal  and  reuse  options.  The process  began  with the
Long  Range  Utilization Project Work Plan  prepared by  Metro in
1980,  followed  by a  Cost  Effectiveness Analysis of Systemwide
Sludge, which was subsequently updated in 1982.

     The  1980  Metro work plan  included ten options  for  sludge
disposal  or  reuse.   The ten basic options were  expanded  to 16
options   in   Metro's  1980  cost-effectiveness   analysis.    In
September  1982,  Metro  determined  that  an  update  of the  1980
cost-effectiveness  analysis was  necessary  since  a number  of
basic assumptions and conditions regarding sludge  management had
changed since 1980.

     The broad categories of sludge management considered in the
1982  cost-effectiveness  analysis  and  analyzed   in  this  EIS
include:

     o  Agriculture
     o  Composting
     o  Dry Sludge Product
     o  Incineration
     o  Landfilling
     o  Ocean Disposal
     o  Silviculture
     o  Soil Improvement
                               46

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     A  necessary feature  for all  the above  sludge management
categories  is sludge  processing at  the West  Point  or Renton
treatment  plants.   Sludge processing  components  include sludge
thickening, anaerobic  digestion,  and  dewatering to either 18 or
40  percent   solids  content.   Many  of  the  necessary  sludge
processing  facilities  currently  exist  at   the  West  Point
Treatment  Plant.   Because  of  the  lack  of  existing  sludge
processing  at the  Renton  Plant, Metro's  alternatives analysis
has included  a greater number of sludge management alternatives
for Renton than  considered for West Point.
Description of All Alternatives

     From   the   10  broad   categories  of   sludge  management
previously mentioned, Metro defined 18 project alternatives; one
agricultural    application    alternative,     four    composting
alternatives,   one  dry   sludge  product   alternative,   three
incineration  alternatives,  two  land-filling  alternatives,  one
ocean disposal alternative, four silvicultural alternatives, and
two soil reclamation alternatives.  Table 2-4 presents a 'summary
description of  the alternatives and  their  present  worth costs.
The apparent least cost alternative for the Renton plant assumes
ocean disposal, a method no longer allowed because of the Marine
Protection,  Research,   and  Sanctuaries  Act;  the  most  costly
alternative (Alternative 3) calls for construction and operation
of a facility to produce a dry sludge product for sale as a soil
conditioner.   For   the   West  Point  plant,  the   least  cost
alternative is soil improvement at a public/private site located
within  10  miles  of  the treatment  plant  (Alternative  8a) ;  the
most costly alternative  (Alternative  8c)  is to  a  site  within a
maximum distance  (180 miles) of the treatment plant.


Metro's Screening and Selection Process

     Metro's  selection  of alternatives  for  final  consideration
was  accomplished  by  conducting analyses  of  monetary  (capital
costs,  operation   and  maintenance  costs,  and  land  costs)  and
nonmonetary  (environmental  factors, energy  use  considerations,
and  subjective  factors  such  as  reliability, flexibility,  and
agency and public acceptance) factors.  A detailed account of the
alternatives  analyses  is presented in the Sludge  Disposal  and
Reuse  Cost-Effectiveness Evaluation   (1983b), part  of  Metro's
Draft  Sludge Management Plan   (1983a) .   As  a  result  of  the
screening and evaluation process, Metro  defined  alternatives as
either   rejected,   deferred,    or    recommended  for   further
consideration.
Alternatives Rejected or Deferred by Metro
     Of -the  18  initial project alternatives,  five  were dropped
from further  consideration because of  high  costs,  unacceptable
nonmonetary factors or a combination  of the  two.   An additional
                              47

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                           Table 2-4.  Description of Long-Term Sludge Management Alternatives
Alternative
Description
Total Cost (Present
Worth, Millions)
1 - Agricultural application
2A - Tank composting
  (digested sludge)
2B   Pile congesting
   -1 18% solids
   -2 40% solids
2C - Tank composting
  (undigested sludge)
3 - Dry sludge product
4A - Thermal conditioning
 and incineration
4B - Co-incineration with
 municipal solid waste
4C - Carver-Greenfield
 and incineration
Primary sludge  from West  Point  or combined prijnary and thick-
ened secondary  sludges  from Renton (18% solids)  would be
trucked 45-190  miles, stored in lagoons and applied onto pri-
vate agricultural  land  using direct  subsurface injection.
Land requirement is 11,000  acres for 100% of sludge produced
annually.

Anaerobically digested  sludge (18% solids)  would be composted
using a Turbitol Company  tank composter.   Processing would be
done at the Renton and  West Point Treatment Plants.   Com-
posted sludge would be  generated at  a rate of 150-190 cubic
yards per day and  would sell for $2.50 per cubic yard.

Anaerobically digested  sludge (either 18% or 40% solids)
would be composted using  pile composting.   Sludge would be
trucked to a 14 to 24-acre  Metro facility in the Kent Valley
industrial area.   Composted sludge would  be generated at a rate
of 150-350 cubic yards  per  day  and would  sell for $2.50 per
cubic yard.

Primary and thickened secondary undigested sludges (18% solids)
would be coexisted at the Renton plant using a Turbitol Company
tank processing system.   No anaerobic digesters  would be used
at the Renton plant.  Composted sludge would be  generated
at a rate of 150-190 cubic  yards per day  and would sell for
$2.50 per cubic yard.
Undigested  (raw),  dewatered sludge would be dried at the
Renton plant using direct/indirect rotary dryers to  produce
a dried sludge  product  for  use  as a  soil conditioner.   Sludge
from West Point would probably  be applied to land.   Metro
would sell the  dried product at $86.00 per ton.

Undigested  (raw),  dewatered sludge would be thermally condi-
tioned by a Zimpro low  pressure oxidation  process to form
a dry sludge cake.  The sludge  cake  would be combusted in
a multiple-hearth  furnace to produce steam or hot water for
space heating or electricity.   Ash would  be disposed of at
the Cedar Hills landfill.   The  incineration facility would
be constructed  at  the Renton plant only.

A non-Metro co-incineration facility would be installed
at an industrial site in  the Duwamish industrial area.
Undigested  (raw) sludge would be chemically conditioned
and dewatered to a solid  cake,  transported by truck  to
the facility, and  incinerated.
Metro would utilize a Carver-Greenfield method of drying
and energy recovery prior to incineration.
West Point:
Renton:
West Point:
Renton;
West Point:
Renton:
$28.3-45.3
$74.2-83.8
$46.9
$87.4
$45.3-51.5
$82.8-87.5
West Point:  NA
Renton:      $83.5
West Point:
Renton:
KA
$1153
West Point:  NA
Renton:      $81.6
West Point: NA
Renton: $99.1
West Point:  NA
Renton: $108.8
5A - Landfill - 18%  sludge
 disposal
Anaerobically-digested and dewatered sludge  (18 percent
solids) would be trucked to a landfill  (within 40 miles
of Seattle) and disposed of with municipal solid wastes.
Metro would pay the landfill owner/operator a tipping fee
of $10.50 to $25.00 par wet ton of sludrje.
West Point:
Renton:
$20.6-36.1
$72.0-81.5
SB - Landfill - 40% sludge
 cake disposal
6 - Ocean disposal
7A - Silvicultural
 application - private or
 public forestlands with
 Metro-owned demonstration
 site
Anaerobically-digested and dewatered  (40% solids) sludge         West Point:   $41.0-53.5
would be trucked to a landfill  (within 40 miles of Seattle)      Renton:       $77.6-84.5
and disposed of with municipal solid wastes.  Metro would pay
the landfill owner/operator a tipping fee of $10.50-$25.00
per wet ton of sludge.

Liquid anaerobically-digested sludge would be transferred        West Point:   $32.3
to holding tanks and then onto large barges.  Once a week        Renton:       $63.9
the sludge would be barged approximately 50 miles off  the
Washington coast and dumped.

Anaerobically-digested sludge would be dewatered and trucked     West Point:   $29.  -34.1
to storage lagoons.  Sludge would be spray-applied to  forest-    Renton:       $77.3-80.8
land from July through January.  Approximately 41,000  acres
of land (within 30-95 miles from Seattle) would be needed to
handle 100% of the sludge production from 1990-2000.   Sludge
would be applied once during the planning period at a  rate
of 20 dry tons per acre.
                                                          48

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                                                   Table 2-4 .  Cont'd.
Alternative
Description
Total Cost  (Present
Worth, Millions)
7B - Silvicultural
 application - Metro-owned
 poplar forestlands
7C - Silvicultural
 application - Metro-owned
 multiple use lands
7D - Silvicultural
 application - private or
 public forestlands with
 Metro-owned backup site
Anaerobically-digested sludge  (18% solids) would be applied      West Point:  $38.0-38.4
at a rate of 10 dry tons per acre per year to 5,500 acres of     Renton:      $84.7-85.9
hybrid poplar forestland (located within 45 miles of Seattle).
Poplar would be harvested and sold to an energy producer for
the generation of electricity.
Anaerobically-digested sludge  (18% solids) would be applied      West Point:  $48.4-48.8
once during the planning period to 26,500 acres of land          Renton:      $94.4-95.5
(located within 45 miles of Seattle)  at a rate of 10 dry tons
per acre.  Douglas-fir would be harvested once every 50 years,
with commercial thinnings at 20, 30,  and 40 years.
This alternative would be the same, as Alternative 7A except      West Point:  $31.9-36.2
that Metro would purchase 2,700 acres of land to ensure that     Renton:      $79.3-82.8
land would always be available for sludge application.
8A - Soil improvement -
public and private land


8B - Soil improvement -
land owned by WIDCO



Anaerobically-digested and dewatered sludge (18% or 40%
solids) would be trucked to- storage lagoons or storage sites,
applied to the land and disked into the top 18-24 inches of
soil. Sludge application would occur from June to September.
Land would be located 10-180 miles from Seattle and owned
by entities other than Metro.

This alternative would be the same as Alternative 8A except
that land would be owned by WIDCO and Metro would pay $10
per ton of wet sludge delivered. WIDCO would be responsible
for all application and monitoring aspects.



West Point: 18% solids -
$19.1-38.9
40% solids -
$41.0-61.4
Renton: 18% solids -
$72.1-83.3
40% solids -
$78.2-89.4
West Point: 18% solids -
$27.7
40% solids -
$46.6
Renton: 18% solids -
$76.5
40% solids -
$80.9
Cost Assumptions:  Year 2000 design year truck transportation only.  Electricity costs $.022-.028/KwH.   Interest assumed
                   at 7 5/8 percent ENR 4500.

Note:  More detailed cost assumptions available in Metro's Sludge disposal and reuse cost-effectiveness evaluation
        (Metro 1983b).
                                                        49

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four alternatives were considered as "deferred" alternatives not
presently feasible for near-term implementation, but which might
at some later date be more closely considered.

     The rejected and deferred alternatives were as follows:

     Rejected

     o  2C  Raw sludge composting
     o  3   Dry sludge product
     o  4A  Thermal conditioning and incineration
     o  5A  Disposal into landfill, 18 percent solids
     o  5B  Disposal into landfill, 40 percent solids

     Deferred

     o  2B-2  Pile composting - 40 percent solids
     o  6     Ocean disposal
     o  4B    Coincineration with municipal solid waste
     o  4C    Multiple effect drying and incineration

     Alternative  2C  -  Raw Sludge  Composting.  Metro  rejected
this alternativebecausenoenergy wouldbe  produced  to offset
the energy  consumed by  composting.  No  energy would be produced
because the alternatives  would  not  include  anaerobic digestion,
a  sludge  treatment  process that produces methane  gas  which can
be used to provide heat or electrical power.

     Alternative  3 -  Dry Sludge Product.   This  alternative was
rejected because  of  high present worth cost  and the  absence of
anaerobic digestion to recover energy -

     Alternative  4A  -  Thermal  Conditioning  with  Incineration.
Metro rejected this alternative  because  of  the large net amount
of  energy  required   for  operation   and  because  many  thermal
conditioning  facilities  have  been shut down  across  the country
because of reliability, odor,  or other operational problems.

     Alternative  5A - Disposal into Landfill, 18 Percent Solids.
Metro  rejected  Alternative  5A  for  the  reasons  defined  in
Alternative 5B.

     Alternative  5B - Disposal into Landfill, 40 Percent Solids.
Me t r o  rejected  Alternative  5B  because  of   the  higher  costs
associated  with  dewatering sludge  to 40  percent, the  lack of
beneficial sludge reuse, and opposition from  landfill owners.

     Alternative  2B-2   -  Pile  Composting,   40 Percent  Solids.
Metro deferred this alternative because pile  composting using 40
percent  solids  provided  no  savings   in  transportation  energy
costs when  compared  to pile composting with  18  percent solids.
However, the  alternative  might  be  reconsidered at  a future date
when the use of 40 percent solids might become more feasible.
                              50

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     Alternative 4B - Coincineration with Municipal Solid Waste.
Metro deferred this alternative  because  of - technical,  financial
and operational uncertainties.

     Alternative 4C -  Multiple Hearth Drying  and Incineration.
This  alternative  was   deferred   because  of  the  uncertainties
associated with an unproven technology.

     Alternative 6 - Ocean Disposal.  Because ocean disposal was
judged  to  be  the  least  costly  alternative, Metro  recommended
deferral of  this  alternative.   If  the  federal  prohibition  of
ocean disposal is  changed  in  the future, Metro  would reconsider
this alternative.
Detailed Description of Feasible Alternatives

     Of the  18  initial alternatives evaluated by  Metro,  9 were
recommended  for additional  evaluation.   These alternatives were
as follows:

     o  Agricultural Application
           Alternative 1
     o  Composting
           Alternative 2A - Tank composting
           Alternative 2B-1 - Pile composting, 18 percent solids
     o  Silvicultural Application
           Alternative 7A - Public/private forestlands with
           Metro-owned demonstration site
           Alternative 7B - Metro-owned poplar forestlands
           Alternative 7C - Metro-owned multiple use forest-
           lands
           Alternative 7D - Public/private forestlands with
           Metro-owned backup site
     o  Soil Improvement
        -  Alternative 8A - Soil improvement of public/private
           land
           Alternative 8B - Soil improvement at WIDCO

     The  following sections  include a  general description  of
each  broad  category  of sludge  management  (i.e.,.  agricultural
application,  composting,  landfilling,   silviculture,  and  soil
improvement)  followed  by  a more  detailed description of  each
feasible  alternative  being considered by  Metro.  The  costs  of
these alternatives are compared in Table 2-5.

     Agricultural Application.  Approximately  16 percent  of all
sewage  sludge generated  in  the   United  States is  applied  to
agricultural  land  for  the  production of  food  chain  crops for
direct  human consumption or  food chain  crops  for  animal  feed
(Peter  in  Bledsoe  1981) .   Application  of sludge to agricultural
land is one  of the more popular methods of sludge reuse by small
municipal  treatment  facilities  having  small  volumes and  low
concentration of trace metals in sludge.
                               51

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                                                   Table  2-5.  Costs of Feasible Alternatives
Ul
Alternative
AGRICULTURAL APPLICATION
Alternative 1
- Western Washington
- Eastern Washington
COMPOSTING
Alternative 2A
(Tank composting)
Alternative 2B-1
(Pile composting - 18% solids)
SILVICULTURAL APPLICATION
Alternative 7A
(Public/private forestlands with
Metro-owned demonstration site)
Alternative 7B
(Metro-owned poplar forestland)
Capital Costs Year 2000 O4M Costs
($ million) (S million) l
Renton West Point Renton West Point
61.9 5.1 3.5 2.7
61.3 5.8 5.1 4.1
83.0 32.3 2.5 1.6
77.5 23.6 2.3 2.5
66.6 6.5 3.2-3.8 2.4-3.1
66.6 8.3 2.9-3.1 2.3-2.4
Present Worth Costs
($ million)1

Renton West Point
74.2 28.3
83.8 45.3
87.4 46.9
87.5 45.3
77.3-80.8 29.8-34
84.7-85.9 38.0-38
.1
.4
           Alternative  7C
            (Metro-owned multiple use  forest-
            lands)                                  66.6

           Alternative  7D
            (Public/private forestlands with
            Metro-owned backup  site)                66.6

           SOIL  IMPROVEMENT

           Alternative  8A
            (Soil  improvement of public or
            private  land)                           62.1

           Alternative  8B
            (Soil  improvement at WIDCO)              62.1
7.2



6.5





2.8


2.7
2.9-3.2



3.2-3.8





3.2-4.9


  3.9
2.5-2.6



2.4-3.1





2.3-4.1


  3.0
94.4-95.5    48.4-48.8
79.3-82.8    31.9-36.2
72.1-83.3    19.1-38.9
                                            76.5
                                                          27.7
            NOTES:  1Lower costs  for minimum  trucking  distance;  higher  costs for maximum trucking distance.

                   All costs expressed as mid-1983 dollars with no  inflation factor.   Discount rates S 7 5/8 percent; ENR of 4500;
                   accuracy within +50 to -30  percent.
            SOURCE:  Metro 1983b.

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     Sludge   applied   to   agricultural   land   is   known   to
beneficially  recycle   nutrients   (nitrogen,   phosphorous,  'and
potassium)  and  to  improve  the  physical  properties  of  soil
(increased water  infiltration;  increased water-holding capacity
and  water  content).   For most  plant  varieties,  sludge  can
provide nitrogen  adequate  to  meet  annual requirements.   One ton
of dry sludge solids with  an  organic  content  of 3.0  percent and
an inorganic nitrogen content (NH4+)  of  0.5 percent  can provide
22 pounds of nitrogen (DOE 1982a).

     EPA  (40  CFR, Part 257)  has  identified  the  most  critical
factors  for sludge  application for  production  of  food  chain
crops to  be soil  pH,  sludge  cadmium concentration,  sludge PCB
concentration, disease  vector control,   and pathogen reduction.
For all food chain crops  for  direct human consumption,  the soil
pH must   be  kept  at or  above  6.5  unless the  sludge  cadmium
concentration is  less than or equal to  2 mg/kg.   If soil  pH is
6.5 or greater,  up to  0.5 kg/ha (0.45 Ibs/acre)  of  cadmium can
be applied annually  with  a cumulative application of 5-20  kg/ha
(4.5-18  Ibs/acre), depending on  the  cation  exchange  capacity
(CEC)  of  the  soil  (40  CFR,  Part 257) .   CEC  is  defined as the
ability of soil  to hold positively  charged  cations.   The CEC is
expressed in milliequivalents per 100 grams of soil  (meq/100 g).

     Sludge can be applied to the surface or beneath  the surface
of agricultural  land using either irrigation or  tank  vehicles.
In the  Best Management Practices  for Use  of  Municipal  Sewage
Sludge the DOE (1982a)   recommends that sludge  be either injected
into the  soil, or if surface applied, it  should  be  immediately
plowed into the soil to control odors and to achieve  maximum use
of nitrogen.

     Crops vary  in their  reaction  to  sludge-enriched soils (EPA
1976a) .   Some crops  may take up and  accumulate trace  elements.
As a general  rule, the leafy portions of  plants  contain higher
levels of trace metals  than found  in  seed heads or flowers (EPA
1976a).   Leafy vegetables  such  as lettuce, spinach,  chard,  and
tobacco tend  to   accumulate  heavy  metals  such  as cadmium more
than do other varieties of plants.

     The  DOE  (1982a) has .established guidelines -and  suggested
management practices for protection of food crops:

     1. Raw sludge should not be applied to agricultural land.
     2. Sludge should not  be  applied to soil the year  the soil
        is used for root crops unless the sludge has  undergone a
        process   to    further   reduce   pathogens   (see    DOE
        Guidelines).
     3. Sludge  should  not be  applied  to  vegetables  through
        irrigation  systems,  or by   other  methods  that  place
        sludge on the crop.
     4. Whenever   possible  the sludge should  be  applied  before
        planting, with immediate incorporation.   Grain crops are
        preferred.
                               53

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     5.  Sludge applied to forage land (green chop, silage, hay,
        or pasture)  should immediately  follow mowing,  so  that
        sludge is not deposited on plant leaves and subsequently
        ingested by livestock.
     6.  Sludge,  soils,   and  plants  should  be  subjected to  a
        testing  program  that  will  provide background  data  and
        evaluate potential accumulation of heavy metals in soils
        and plants.
     7.  The  fertilizer  guide  published  by  Washington  State
        University for the  appropriate  crop  should  be followed
        to identify fertility  requirements as a.basis for sludge
        application.
     8.  When  practical,   sludge  should  be  applied  to  nonfood
        crops such as turf, ornamentals, and Christmas trees.

     Metro identified  one recommended  agricultural  application
alternatives from the 17  initial alternatives.  A description of
that alternative follows.

     Alternative  1  - Agricultural  Application —  The  goal of
Alternative  1  is  to  beneficially use  stabilized,  dewatered
sludge to supply nitrogen and  other nutrients to nondirect crops
other than food chain crops for direct human consumption.  Under
this  alternative,  anaerobically-digested  primary  sludge  from
West Point and combined  primary and thickened secondary sludge
from Renton would be dewatered to  18 percent solids  and trucked
to storage lagoons  at  agricultural sites  in  western  or eastern
Washington.  Sludge  would  be  applied at an  annual  loading  rate
of 3.1  dry tons  per acre to  privately-owned  agricultural  land.
using  an  application   vehicle   equipped  with   a   subsurface
injection  device.   The  one-way  distance  of  agricultural  land
from the  treatment  facilities  could range  from  45-190  miles.
Assuming an annual sludge loading rate of 3.1 dry tons per acre,
approximately  6,290  acres  of  agricultural land would  be needed
to  accommodate   100  percent  of   the   projected  1985  sludge
quantities.

     If sludge application were  to  occur  in  western Washington,
sludge would be  hauled to a 100-acre storage lagoon  site having
a capacity  of approximately  36  million gallons  (equivalent of
year 2000 annual  sludge  production).  Sludge  would be  applied 8
months of  the year.   Lime would  be applied  every  3  years to
adjust the soil pH above  6.5.

     If sludge application were  to  occur  in  eastern Washington,
sludge would  be  hauled  to one  of  9  storage  lagoons  (3,3-4.2
million gallon  capacity  each).   Sludge application  would occur
10 months  per year;  no   liming  would  be  necessary because pH
levels of eastern Washington soils exceed 6.5.

     Composting.    Sludge   composting   involves  the   aerobic
decomposition  of organic  constituents  to  a  relatively  stable
humus-like material.   While sludge is not rendered totally inert
by composting,  in-vessel or  static aerated  pile  composting is
considered by EPA to be a process to further reduce pathogens.
                               54

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     Composting  can be  accomplished  in several  ways:   windrow
method,  aerated  static  pile  method   (individual  or  extended
piles)  or within  enclosed  containers   (tanks).  Although each
technique  is  unique,   the   fundamental  process  is  similar.
Requirements  include  bulking  agents   (such  as  wood chips  or
sawdust), internal  temperature  ranging  from 130-150°  F.  (55-65°
C.) to ensure destruction of pathogens, extended-term storage of
compost, and final  separation of  bulking agent and  compost (EPA
1979a).

     The  composting procedure  involves  mixing raw or  digested
sludge with the bulking agent and,piling the mixture in a windrow
or  pile  or storing  in an enclosed  container.  As the  organic
material  decomposes,  heat generated by  the microorganisms will
raise the temperatures in the compost pile.

     Composting is  common  throughout much  of Western  Europe and
to  a  more  limited extent  in the  United  States.  The  compost
product  is  normally  used  as  a  mulch,  soil conditioner,  or
bedding material for landscaping and nursery stock (DOE 1982a).

     Metro  recommended  composting  alternatives  (2A  and  2B-1)
from  the  initial  18 alternatives.  A  detailed  description  of
these alternatives  follows.

     Alternative   2A   -   Tank  Composting   --   Alternative  2A
involves  use  of a  Taulman-Weiss  tank  composting processing  on
Metro-owned land at the Renton and West Point treatment plants
beginning in 1988.   Tank composting has been utilized in Europe.
but not to a great extent in the United STates.

     Under  this   alternative,   anaerobically  digested   sludge
dewatered to 18 percent solids would be mixed with wood chips or
another  bulking agent  and  placed  within  the bioreactor,  the
first  of  two  vertical,  cylindrical,  enclosed  Taulman-Weiss
tanks.  After  14  days of  composting within the  bioreactor,  the
composted  sludge  would  be  transferred  to  a  cure  reactor  for
14-20  days.   The  entire  composting  process  would   take  28-34
days.

     In  order  to  accommodate  the  projected  year  2000  sludge
quantities, 7 bioreactors and 4 cure reactors would be needed at
the  Renton  Treatment  Plant,  and   6   bioreactors  and  2  cure
reactors would be needed at West Point.

     Alternative 2B-1  - Pile Composting,  18  Percent Solids  —
Alternative  2B  involves  composting  of anaerobically  digested
sludge  (18  percent  solids)   processed  at  the Renton and West
Point  treatment   plants   in the   same  manner  as   previously
described.  Sludge would be trucked to a 24-acre composting site
in  the Kent Valley industrial area, stockpiled,  and  mixed with
wood chips in a 3:1 chips-to-sludge ratio.   The mixture would be
placed  in  10-foot-high  static  piles  aerated from  underneath
using a piping and fan system.  The time required for composting
                               55

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would be 28 days of  aeration  time  followed by 5 days of drying.
The composted product would be  sold by the contractor to public
and  private  users  such   as  highway  departments,  landscapers
nursery men, and possibly the general public.

     Silvicultural Application.   The  application of  sludge to
forestlands  is  a  relatively   new  concept.   Most  available
information  derives   from  studies   conducted  in  Pennsylvania,
Michigan, and Washington.   The greatest amount of sludge forest-
land   application   research  has   been  accomplished   at  the
University of Washington's Pack Forest.

     Research  studies  have shown  that  sludge is  suitable for
application on Douglas-fir, cottonwood, poplar, and Sitka spruce
but that western hemlock,  red cedar and red alder do not respond
well to  sludge amended conditions  (DOE 1982a).  Sludge  can be
applied  to:    1)  recently   logged  forestlands,  2)   recently
established plantations,  or  3)  well established  forests  using
either  spreading  or  spray application  methods.    Studies  have
shown  that  sludge  must  be allowed to dry  for at  least 6 months
prior  to planting  seedlings  on recently logged sites,  but that
sludge can  be spray-applied  over young  established plantations
(seedling  age  5   years or older).   Application  of  sludge  to
established forests  has been  studied more  than other forestland
options.  As  a  part  of its research program,  the University of
Washington  has  studied  the  nitrogen  needs  of  forestlands  in
Western Washington.  The  research  has shown  that up  to  43 tons
of sludge per acre (approximate depth of 2 inches) is sufficient
to meet the nitrogen needs of a forest site over a 5-year period
(DOE 1982a).

     The  methods  of applying  sludge  proven  to  be  the  most
effective  to  date include  use of  a spray  application  vehicle
mounted with a  sludge storage tank  and cannon-type spray nozzle
for distributing sludge up to 150 feet from the vehicle.   Access
roads  spaced 250 feet apart allow for  proper sludge coverage of
each site.

     The DOE  (1982a)  has   indicated  a number  of  advantages for
using  forestlands  in Western Washington for sludge application:

     1. Extensive  acreages of suitable forestland are located
        within a reasonable hauling distance  from municipal
        treatment plant facilities.
     2. A substantial number of these forestlands are located on
        well-drained  sites  and  are not  subjected  to periodic
        flooding.
     3. Many of  the  forestlands are markedly  deficient  in the
        nutrients  found in municipal sludge, especially nitrogen
        and phosphorous.
     4. Public     health    concerns    and    land-application
        regulations,   particularly   those   related   to   heavy
        metals,   are   a    less   critical    consideration   for
        nonfood  chain  crops   than   for  those used  for  human
        consumption.
                               56

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     5. In  general,  year-round  application   schedules  can  be
        maintained,  minimizing  storage  needs  and  off-season
        disposal demands.

     Metro  identified  three  feasible  silvicultural application
alternatives:  Alternative  7A, Public/private  forestlands with
Metro-owned  demonstration  site;  Alternative  7B,  Metro-owned
poplar  forestlands;  and Alternative  7C,  Public/private forest-
lands with Metro-owned backup site.

     Alternative  7A  -  Public  or   Private   Forestlands  with
Metro-Owned  Demonstration  Site —   This alternative  calls for
sludge  processing  at  Renton  and  West  Point  consisting  of
thickening,  anaerobic  digestion  and  dewatering  to  18  percent
solids.  Metro  would initiate  sludge  application in  1985  on a
Metro-owned  640-acre demonstration  site.  Facilities  for  the
site would  include  one  36-million-gallon storage  lagoon, access
roads, operation buildings, fencing,  one lagoon tractor, and one
sludge  application  vehicle.   Sludge  would be  applied  at a rate
of 20  dry  tons per  acre  for  each of  the years  1985,  1986, and
1987.   Site  monitoring  of  soils,  surface water,  groundwater and
plant tissue would  be carried out during sludge application and
for 5 years after the last application.

     Beginning   in   1990,  Metro  would   initiate   full-scale
silvicultural application on 41,000 acres of public or privately
owned land.  Sludge  from  the  Renton  and West  Point plants would
be transported  by  30-cubic-yard  capacity trucks  to the  36  MG
storage lagoon.  Sludge application would occur 9 months of each
year,  using lagoon  tractors  and pumps,  6,000-gallon-capacity
nurse tankers (to transport sludge from the lagoon to the actual
application  sites)  and  applicatio'n  vehicles.  The  application
sites  would be  located 30-95  miles   from  the Renton  and  West
Point treatment plants.

     Alternative 7B  - Metro-Owned Poplar Forestlands —  Sludge
processing  for this  alternative would be the  same  as described
for Alternative  7A.   This alternative  assumes that  Metro would
purchase 5,440 acres (the 640-acre demonstration site plus 4,300
acres  in  1989 and  500  acres  in 1994) ,  clear the  land,  plant
poplar, apply sludge at 10, dry tons per acre per y.ear, and after
7  years harvest the  timber  for sale as  a  fuel  source  for
generation and after 7 years of electricity.  The facilities and
equipment  needed for implementation  of this  alternative  would
include a 36 MG lagoon,  2 lagoon tractors and 3 pumps, 5 nurse
tankers, and 8  sludge  application vehicles.  Approximately  71
dry  tons   of poplar would  be  harvested  per acre  per  year.
Revenues derived  from methane recapture and  sale  of wood would
amount to approximately $1.1 million during the year 2000.

     Alternative  1C  - Metro-Owned Multiple Use  Forestlands  —
With Alternative 7C, sludge processing would  be  the  same as for
Alternatives 7A  and 7B.  Metro would purchase 26,500  acres  of
logged  forestlands   to   grow   trees  for   timber   revenues.
                                57

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Immediately following  purchase of  land,  10 dry tons  of sludge
per acre  would be  applied and  the site  planted  with  a grass
cover  crop.   During  the  fall,  Douglas-fir seedlings  would be
planted on the  grassy  sites,  and 5 years  later  sludge would be
applied at a rate of 20 dry tons per acre.

     Public access to  the  land would be  restricted for a 1 year
period  after  sludge  application.   All  other  land  would  be
available  for  multiple use   activities.   The  facilities  and
equipment needed would  include  1  36 MG storage lagoon, 2 lagoon
tractors,  3  lagoon  pumps,  8  nurse  tankers,  and  8  application
vehicles.

     Alternative   7D   -   Private/Public   Forestlands   with
Metro-Owned   Backup   Site  —    Sludge   processing   for  this
alternative would be the same  as  previously described for other
silvicultural alternatives.  This alternative  would  be the same
as Alternative  7A except  that  Metro would also purchase 2,700
acres  of  land as  a backup  site for  sludge management.   The same
equipment  and  facilities  needs as  for Alternative 7A would be
used for this alternative.

     Soil  Improvement.  The  use  of  sludge   to   improve  soils
deficient  in  nutrients and organic material has  received more
recognition  in  recent  years.   Surface-mined  land  has  been
reclaimed  using sludge in Pennsylvania,  Illinois,  Washington,
Minnesota, and  West Virginia  (Sopper  and  Kerr  1979;  Frank i..
Sludge Magazine 1978).  In  Washington, Metro  has  conducted soil
improvement projects at West  Point Beach Park;  along the Lake
Sammamish  interceptor  right-of-way; at  Boeing Field, Gasworks
Park,  Myrtle  Edwards Park, and Grain  Terminal Waterfront Park;
at WIDCO  in Centralia;  and  at  the Grouse Ridge borrow pit owned
by Weyerhaeuser Company (Hubbard ir\ Bledsoe 1981) .

     Use of sludge for soil improvement  includes  sludge storage
in  lagoons,   sludge   application,   disking,  final  grading  and
seeding.   Application  can  be  accomplished  by:    1)   spray
irrigation,  2)  direct  dumping from haul trucks,  3)  broadcast
spreading with  commercial  fertilizer spreaders,  4) nurse trucks
or pipelines  attached to  cultivater tools, and 5)  direct soil
injection  by  mobile all-terrain  tankers equipped with rippers
and injection tubes  (DOE 1982a).

     Sludge for use at land reclamation sites is usually held in
the storage lagoons until application in the spring,  summer, and
fall  months.   Application  rates vary  with the  site,  type of
soil,  and other factors.   Long term sludge application requires
site monitoring  to assess  the  impact  of  sludge application on
surface water,  groundwater,  and  soils, and to provide an early
warning of any  adverse  impacts  (DOE 1982a).  Sludge  application
rates  are  typically  higher   than   those  for  silviculture  or
agricultural uses, particularly  if  no  sensitive  groundwater and
surface water resources occur near the application site.
                               58

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     Two soil  improvement  alternatives were considered feasible
by Metro - Alternative 8A, Soil improvement of public or private
land, and Alternative 8B, Soil Improvement at WIDCO.

     Alternative  8A -  Soil  Improvement of  Public  or  Private
Land --  The  in-plant processing  for this alternative at Renton
and  West  Point would  include thickening,  anaerobic digestion,
and dewatering to 18 percent solids.  Sludge would be trucked to
a  36 MG  storage  lagoon  holding   area  in  the  Kent  Valley  and
thence  to  application   sites  located  35-155  miles  (one-way)
distance  from the  storage  area.   The  storage  lagoon would be
sized to handle year 2000 sludge volumes.

     Sludge  at the application sites would be  end-dumped from
trucks and disked  into  the  soil using a D-8 caterpillar tractor
with  an  8-foot-wide  disk.   A  grass  cover would  be  planted
immediately after final disking.  Sludge application would occur
4 months of each year at a rate of 120 dry tons/acre/year.  From
220-300  acres  of.  land  would  be  needed  each   year  for  this
alternative.

     Under this alternative Metro might consider the application
of sludge as  a landfill  cover  (top dressing)  at  the Cedar Hills
and  Duvall  landfills.   The  application  of  sludge as  a  top
dressing involves mixing the  sludge with soil and  applying  the
mixture as  cover  material on the  landfill.   The  cover  material
is then seeded with a grass seed to bind the soil and to prevent
surface erosion.  Best Management Practices for use of municipal
sewage sludge  as a landfill top dressing have been identified by
the DOE (1982a).

     Alternative 8B - Soil Improvement at WIDCO —  The  in-plant
sludge  processing  for  this alternative  would  be  the  same  as
previously  described  for  Alternative  8A.   Sludge  would  be
transported,  stored,  and  trucked  to WIDCO  in  much the  same
manner as previously described for Alternative 8A.

     Sludge  would be trucked  year-round to  sludge  lagoons  at
WIDCO.  Metro  would pay a  tipping fee of  $10  per wet ton  and
WIDCO  would  be  responsible  for  on-site  handling  and  site
monitoring.


              Metro's Preferred Long-Range Sludge
                       Management Program


Goals of the Preferred Plan

     Metro has  defined  four long-range  sludge management goals
relevant to various components  of  the preferred  program.   These
goals are to:
                               59

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     o  Implement land  application of  sludge  as  the  preferred
        management   strategy,   including   soil   improvement,
        agricultural application,  silvicultural  application and
        production,  and marketing of a composted sludge product
     o  Continue  anaerobic  digestion  and  dewatering  to  18
        percent  soils  at  the West  Point  Treatment Plant  and
        incorporate  the same processing at  the  Renton Treatment
        Plant.
     o  Identify land application sites capable of accommodating
        150 percent  of the projected annual sludge quantity.
     o  Secure land  application sites at least  1 year in advance
        of project startup.

     In addition  to these broad  goals,  Metro  has  identified  a
number  of  goals specific  to  soil  improvement,  agricultural
application,  silviculture and  compost production.   These  goals
are listed in Table  2-6.
Elements of the Preferred Plan

     In-Plant Processing.  Different  in-plant  sludge processing
methods  prior  to  land  application  or  composting  have  been
described   above   for  each   of   the  feasible   alternatives.
Anaerobic digestion with medium dewatering  (18 percent  solids)
have   been   identified  by   Metro   as  recommended   in-plant
processing.

     Sludge Transport.   Different  sludge  transport  methods  for
land  application  or  composting  have been  described above  for
each of  the feasible  alternatives.   Metro has  identified truck
transport as the recommended  transport mode.

     Agricultural  Application.   As   a  part  of  the  Preferred
Sludge Management Plan, Metro proposes  to initiate  a program of
applying  sludge  to  agricultural  land in  Western  or  Eastern
Washington.   Agricultural sites as close as  45  miles and as  far
away as 190  miles could be  cost effective.

     Agricultural   application  could   be   initiated   as   a
demonstration project as early as 1985.  Project  features would
include:

     o  Sludge storage - Western Washington sludge storage would
        be  on   land   purchased  by   Metro,   whereas   Eastern
        Washington  storage  facilities  would  be   located   on
        private agricultural  land.
     o  Rehandling - Sludge would be  removed  from lagoons using
        manure-type pumps,  followed by  loading  into application
        or nursing vehicles.
     o  Sludge  application  -  Sludge  would  be  applied  using
        subsurface injection  systems.
     o  Monitoring -  Metro would  provide  soils and groundwater
        monitoring following  sludge  application.
                              60

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                                  Table 2-6.  Metro's Proposed Sludge Management Goals.

PRIMARY GOALS

     o  Implement land application of sludge as preferred sludge management strategy.  Land application methods include
        soil improvement, agricultural application, silvicultural application and production and marketing of a composted
        sludge product.

     o  Continue anaerobic digestion and moderate  (about 18 percent solids) dewatering at the West Point Treatment Plant.
        Recommend that solids handling facilities at the Renton Treatment Plant be designed to provide anaerobic digestion
        and moderate dewatering.

     o  Identify land application sites capable of taking 150 percent of the projected annual sludge quantity to ensure
        reliable sludge management.

     o  Secure land application sites at least 1 year in advance of project start-up.

     o  Secure a Metro-owned or leased site to provide backup capacity for at least 1 year.

     o  Determine cost and feasibility of improving the quality'of Metro's sludge by minimizing or lessening the concen-
        trations of potentially toxic or hazardous substances entering the treatment plants by a more stringent industrial
        pretreatment program or by treating industrial flows separately.

AGRICULTURAL APPLICATION

     o  Investigate opportunities for implementing agricultural application projects.

COMPOSTED SLUDGE PRODUCT

     o  Maintain existing production capacity either at Sawdust Supply Company (GroCo)  or at alternate public or Metro-
        owned site.

     o  Evaluate different composting methods to determine the most effective method of meeting Metro's current and projected
        composting needs.

     o • Investigate further the potential market for Metro compost.

     o  Implement a marketing program for sludge-derived compost to encourage use within available market.  Use  sludge-
        derived compost for landscaping at Metro transit and wastewater treatment facilities.   Coordinate with local
        governments to use in landscaping of other government facilities.

SILVICULTURAL APPLICATION

     o  When possible, locate projects on land owned by private timber companies  or state/federal  timber management agencies.

     o  To provide capacity and a guaranteed site, purchase land for sludge application.   Focus on land in King  County.

     o  Implement demonstration projects to demonstrate benefits of sludge application  on forest land to landowners and
        surrounding neighbors.  Include extensive monitoring to document effects  on groundwater quality, surface water
        quality,  and wildlife populations.

SOIL IMPROVEMENT

     o  Maintain existing contract with Washington Irrigation and Development Company (WTDCO)  for  sludge use  in  reclamation
        of the strip mine site at Centralia.

     o  Implement additional soil improvement projects as available.

SECONDARY GOALS

     o  In cooperation with WDOE,  investigate possibilities for regional sludge management.

     o  Continue  to support research designed to provide better understanding of  long-term fate and possible  effects
        (beneficial and adverse)  of sludge  constituents in the environment.

     o  Investigate possibilities  for developing management practices which maximize enhancement of plant growth.   In-
        vestigate alternative operational systems which may provide more efficient and  less costly land application methods.

     o  Continue  to monitor regulatory status,  implementation potential  and other agency  experience with sludge management
        alternatives that have been "set aside"  in this document.   Evaluate any new or  different sludge management
        technologies that become available.   Weigh estimated costs  and potential benefits or impacts against present system.
        Report  on any technologies  with potential for Metro implementation  to the Water Quality Committee of  the Metro
       Council.
                                                              61

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Metro would  begin full-scale  sludge application  following the
initiation and review of the demonstration projects.

     Silvicultural Application.   A second component  of Metro's
preferred plan  includesapplication of  sludge  onto forestlands
within a distance of  30-95  miles  from  Metro's treatment plants.
Application  could   be   accomplished  on  private,   public  or
Metro-owned land  (if within 45 miles of the Renton or West Point
treatment plants).  Project features would include:

     o  Sludge  Storage   -   Sludge  would  be   stored in  lagoons
        located  no  greater than  0.75  miles  from  application
        sites.
     o  Rehandling -  Sludge pumps  and  nursing vehicles would be
        needed  for  sludge  rehandling.   Sludge  would  be pumped
        from  lagoons into  nursing  trucks having  6,000-gallon
        capacities.   Sludge  would  be  moved  in  the  nursing
        vehicles  to  the  application sites and  then transferred
        to spray application vehicles.
     o  Sludge  Application  - Sludge  from the  nursing vehicles
        would   be   transferred   to   2,000-gallon   capacity,
        all-.terrain spray application  vehicles.   Those vehicles
        would spray  sludge  into the forest from  skidder trails
        spaced 150-300 feet apart.
     o  Monitoring  -  Metro  has  prepared  a  Sludge-Intensive
        Monitoring  Report   and  a  draft  monitoring  program
        response   plan   for    a    silvicultural   application
        demonstration program  to be  initiated  at  the Pilchuck
        Tree  Farm,  Arlington,  Washington.    Results  of  this
        demonstration program  will provide Metro  with guidance
        needed to establish monitoring needs  for  the long-range
        program.

     Full-scale  silvicultural application  is  not  anticipated to
begin until 1990; however, demonstration projects are planned to
be  initiated  in the  fall of  1983.   A description  of  the  first
demonstration project, at the Pilchuck Tree Farm,  appears in the
discussion of Metro's near-term plan.

     Soil Improvement.  The third component of Metro's preferred
plan is to  utilize  sludge for improvement of soil on disturbed
land located within  10-180  miles  from  Metro's treatment plants.
Metro would utilize DOE's Best Management Practices to determine
suitable sites.   Features of soil improvement would include:

     o  Storage  - Metro  would either develop a  central storage
        lagoon or utilize on-site storage capabilities.
     o  Rehandling - Sludge would  be moved from storage lagoons
        to  nursing  vehicles using  a  sludge  pump  and tractor.
        Nursing   vehicles   would   transport   sludge    to   the
        application sites, and sludge would be off-loaded by use
        of an end-dumping method.
     o  Application - Sludge would be incorporated into the soil
        using a disk plow pulled by a caterpillar tractor.
     o  Monitoring - Site monitoring would be the responsibility
        of Metro or the site owner/operator.

                               62

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     Production  and Marketing  of a  Composted  Sludge  Product.
The  fourth component  of  Metro's preferred  long-term plan  is
development of  a composted  sludge product  to be  marketed and
used  as  a soil  amendment,  mulch,   or  fertilizer  substitute.
Metro has  identified two  possible methods  of sludge composting,
tank  (enclosed  vessel)  and  pile systems;  these  systems  were
previously discussed in this chapter.

     Metro  would have  the  choice of  owning  and operating  a
compost operation or contracting  with a  private party for those
services.   Because  a  composting methodology  has   not  been
selected,  Metro proposes  to initiate  a  number  of  studies  to
assist in the decision, including:

     o  An economic study of ownership of vs contracting for the
        compost facility.
     o  An evaluation of composting methodologies.
     o  A market study to establish market capacity and price for
        a composted product.

     Steps  to  Plan Implementation.   Metro has  identified  four
steps  necessary  prior   to   implementation   of  the   preferred
sludge management plan.  These steps would be necessary for any land
application of sludge.

     1. Develop   and   finalize   key   evaluation   criteria   to
        determine site acceptability.
     2. Develop  an  inventory  of possible  sludge  application
        sites   located  within  a  cost-effective  distance  of
        Metro's Renton and West Point treatment plants.
     3. Evaluate  and  prioritize  sites  based  on  DOE's  Best
        Management Practices for use of municipal sewage sludge.
     4. Initiate detailed site selection process.


                Metro's Preferred Near-Term Plan

     In  addition  to  the  long-range  (20-year)  plan,  Metro's
sludge management planning effort includes a 5-year and a 1-year
(1983)  planning period.   Each is  designed  to provide  a  more
site-specific analysis of sludge management projects and sites.


Five-Year Plan

     Metro's five year  plan will  include  the  following subject
areas:

     o  Plan Objectives
     o  Quantities and Characteristics of Sludge
     o  Project Identification Methods
     o  Evaluation Procedures
     o  Project Implementation
                               63

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     The  five-year  plan  will  present  a  list  of  potential
projects  capable   of   taking  all  of   the   estimated  sludge
production during the planning  period  plus  a  list of sites that
could handle up to an additional 50 percent of the sludge in the
event  the  preferred  sites  cannot  be  utilized.   Metro  has
established a goal of using  35  percent of the sludge production
for soil improvement; 25  percent  for composting;  25 percent for
silviculture; and 15 percent for agricultural use.

     The five-year plan has  not yet been prepared and therefore
is not evaluated in this EIS.  It will, however, be presented in
Metro's final plan and evaluated in the Final EIS.


1983 Plan

     Summary  of  Plan.    Metro  has identified  five  permitted
sludge application sites and a number of sites for which permits
have not been granted to handle the projected 1983 sludge volume
of  77,700  wet  tons  (13,986 dry  tons).   The permitted  sites
include:

     o  WIDCO                   38,000 wet tons (wt)
     o  GroCo                    4,000
     o  Cedar Hills Landfill    15,000
     o  Duvall Landfill          3,000
     o  Pack Forest              2,000
                                62,000

     Other sites  which  have  not  yet received permits  would be
needed  to  accommodate  the additional  15,700 wt of sludge.   One
site  at the  Pilchuck  Tree  Farm,   currently  in  the  permitting
process, may accommodate  8,000  wt  of sludge during 1983.  Other
sites may accommodate the following:

     o  Soil Improvement                     12,000 wt
     o  Agricultural Application (pasture    10,000
        land)
     o  Silviculture for Energy Production    5,000
     o  Powerline Right-of-Way Management     5,000
     o  Composting by Competitive Bid        20,000
                                             52,000

     Pilchuck  Tree  Farm  Demonstration  Project.   Metro  has
initiated acooperative  program to applysludge  on 70  acres of
forestland  on  the  Pilchuck  Tree  Farm,  Arlington,  Washington
(Figure 2-8), as  part of  the 1983  plan.   The  Pilchuck Tree Farm
is owned and operated by the Pacific Denkmann Company.

     The  Pilchuck Tree  Farm  and   Metro  began the cooperative
program  in  1981.   Since  that  time,   Metro   has   undertaken  a
detailed site study of a 2,400-acre portion of the Pilchuck Tree
Farm  called  the  Armstrong  Tract.   Within  that  tract,  Metro
                                64

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                                PILCHUCK TREE
                                     FARM
                                S N 0 H O M I 5 H
 R. A v 5
A K BOP.
             i.   Olympi
                 U R. S> T 0 N .
                 FIGURE 2-8
              Location of the
Pilchuck Tree  Farm, Arlington, Washington
                     65

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identified  340  acres  as  suitable  for  sludge  application.   Of
those  340   acres,   a  70-acre   site  was   selected   for  the
demonstration project  following  completion  of a  detailed site
evaluation.   The   site   evaluation   included   on-site  soils
inspection,   review   of   aerial   photographs,   and   ground
reconnaissance  of  each   site.    Criteria   used  to  determine
suitability  for  sludge application included  soils,  vegetation,
slope,  and  surface  water  characteristics.    Consideration  was
also  given  to  such  factors  as  tree height  and spacing,-  and
existing road systems  (Metro 1983d).

     As  part  of  the  Pilchuck  demonstration  project,  Metro
prepared the following documents:

     o  Preliminary  Draft  Pilchuck  Tree   Farm  Demonstration
        Application  Project  Report  (1983d),   (an  appendix  to
        Metro's Draft Sludge Management Plan 1983a).
     o  Hydrology   report  for   Pilchuck   Tree  Farm   Sludge
        Application Site,  November 1982 (Metro 1982a).
     o  Addendum No.  1 to Preliminary Draft  Pilchuck  Tree Farm
        Demonstration Application Project Report.

     Operation  Plan.    Metro  plans  to  transport 8,000 wt  of
sludge from the West Point Treatment Plant to a storage basin or
storage  tanks  located on  the  Armstrong tract   (Figure  2-9) .
Several storage alternatives are being considered:

     o  A  one-million-gallon  capacity   basin  with   a  30-day
        storage capacity-
     o  A 0.25 MG basin.
     o  A  reusable tank   for  storage of approximately  13,000
        gallons (2 truck loads)  of sludge.
     o  A  haul  truck  trailer  drop-off and  pick-up  for sludge
        storage.

     Table 2-7 presents the projected number  of truck loads and
number of  trucks necessary to provide 8,000 wt of sludge to the
site.  The haul route  from Interstate 5 would be  along State
Route 9 and the Armstrong Road.   Sludge vehicles would return to
State Route  9 via  Brakken  and Grandview Road.  At the request of
the  Pilchuck  Citizens'  Advisory Committee,  sludge would not be
delivered  to the site  on  school  days  for  2  hours in  the morning
and  2.50 hours in the afternoon to avoid school bus hours.

     Sludge  from  the  storage   basin  would  be  pumped  into
all-terrain  application vehicles which  would  apply  sludge onto
the  70-acre  site  using a  remote-control powered,  cannon-type
spray  mechanism.    The spray  mechanism  would  be  capable  of
distributing sludge up to 150  feet from the vehicle.

     Sludge application would occur only  between October 15 and
March 15.  Sludge would be applied  at a rate  of 20 dry tons per
acre  (1-inch depth) over the site.
                               66

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               Sludge
             Application
               Areas
          Sludge Handling
              Area
                                 SOURCE: METRO.1982d
                 FIGURE 2-9
       Proposed Sludge Application
            Sites and Facilities,
Pilchuck  Tree  Farm, Arlington, Washington
                     67

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                             Table  2-7.   Estimated  Truck Loads,  Trips Per Day
                                   and  Hauling Days,  Pilchuck  Tree Farm
                                           Demonstration Project
Ol
oo
Storage
Alternative
One-million-gallon basin
Small basin (0.25 mq)
Reusable tank
o 18% solids content
o 13% solids content
Trailer
Total
Loads
180
185
365
45
320
365

365
520
520
Average/
Day
9
4
9
4

4
5
5
Days of
Hauling
20
46
66
5
80
85

91
104
104
            SOURCE:  Metro  1983d.

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     Site Monitoring.  Metro has  defined  a site monitoring plan
to  be  carried  out  during and  after  sludge  application.   An
intensive  monitoring  program  would  continue  for  12  months
following  sludge  application,  with  less  frequent  sampling  to
continue for 5 years after application.

     Monitoring of the site would include:

     o  Water  Quality -  Water quality  in  test wells  located
        adjacent  to  and  within  the  application site would  be
        monitored.  Water quality testing  would also be carried
        out  at nearby  Kunze  and  Rock  Creeks  and at  springs
        down-slope of the application site.
     o  Forest Productivity - Measurements of growth rate of the
        forest would  be coordinated  by  the Pilchuck  Tree Farm
        management.
     o  Wildlife  -  University  of Washington  researchers  would
        investigate   the   effects  of  sludge   application  on
        wildlife    species.      Monitoring     would    include
        determination  of  changes   in  species  diversity  and
        numbers,  health  of the wildlife,  and  effects  of metals
        and other contaminants.  Metro staff would also evaluate
        impacts on fish populations.

     A more  detailed discussion  of  the  proposed  demonstration
project and impacts of that action  is presented in  Chapter 3  of
the EIS.
           Approach to EIS Evaluation of Alternatives

     Chapter  3  of this  EIS  presents  an  impact  analysis  of
Metro's  long-range   and  near-term   sludge   management  plans.
Chapter  3  is  divided into  two  separate  impact analyses:   an
evaluation of  long-range  (20-year) plan, and an  analysis  of the
proposed Pilchuck  Tree  Farm sludge  demonstration project.   The
analysis of  the  sludge  management  plan  consists of  "generic"
evaluations  of  soil  improvement,  silviculture,  agricultural
application and  composting.  The  Pilchuck  demonstration project
impact  analysis  consists  of detailed  project-level  evaluation.
Chapter  3  of  the  EIS  presents  descriptions of- the  existing
conditions of  the planning area  in  general, and Pilchuck  Tree
Farm in  particular.   It  also identifies mitigation  measures  to
minimize adverse impacts.
                               69

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70

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	Chapters
  Environmental Setting and Impacts of Alternatives
                              •Impacts of Sludge Processing
                  •Impacts of Feasible Long-Range Alternatives
          •Impacts of Metro's Preferred Long-Range Alternatives
                          •Impacts of Metro's Near-Term Plan
 •Impact Analysis of the Pilchuck Tree Farm Demonstration Project

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                            Chapter 3
                ENVIRONMENTAL SETTING AND IMPACTS
                         OF ALTERNATIVES
                          Introduction

     This  chapter  includes  impact  analyses  of:   1)  sludge
processing  features  common  to  all  Metro  long-range  sludge
management  alternatives;  2)  the  long-range  alternatives  of
agricultural application, composting, silvicultural application,
and  soil  improvement;  3) Metro's preferred  long-range program;
4)  Metro's  proposed  near-term  program;   5)   the  no-project
alternative;   and   6)   the  proposed   near-term  silvicultural
application project at the Pilchuck Tree Farm.


                  Impacts of Sludge Processing

     All  of  Metro's proposed project  alternatives, as  well as
the preferred  long-range  and near-term plan  alternatives, would
require  construction of sludge  processing   facilities  at  the
Renton  and  West  Point   treatment  plants.   For  all  feasible
alternatives   considered,   sludge  thickening   and  dewatering
equipment would  be  required at both plants,  whereas  additional
anaerobic  digestion capacity  would be  installed  only  at  the
Renton  Treatment   Plant.    For  the   composting  alternative,
Taulman-Weiss  composting tanks would  be  installed on-site  at
both Renton and West Point.
Renton Treatment Plant

     EPA's Final  EIS  - Wastewater Management Plan  for  the Lake
Washington/Green  River   Basins  (1981a)  included   an  impact
analysis  of  construction,  and  operation  of  proposed  sludge
handling   facilities   at  the   Renton  Treatment   Plant,   and
therefore, will not  be discussed herein.  The  site evaluation,
which   included   a   cultural  resources   survey   and  impact
evaluations,  are hereby incorporated by reference into this EIS.
Energy  consumption  for  sludge  processing,  by   alternative,  is
shown in Table 3-1.

     Taulman-Weiss Tank  Composters.   Alternative  2A calls  for
installation of  7 bioreactor and 4  cure  reactor tanks  at  the
Renton Treatment  Plant.   These  tanks would be  installed  on  the
existing treatment plant  property on a  portion  of  the  property
previously evaluated  in  the  1981 EIS  (EPA 1981a;  Hammond pers.
comm.) .
                               71

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         Table 3-1.  Energy Production for the Various
                     Project Alternatives
Alternative
                                  Million BTUs Produced1
                                        (Year 2000)
West Point
Renton
Alternative 1
  Eastern Washington
  Western Washington

Alternative 2A

Alternative 2B

Alternative 7A

Alternative 7B

Alternative 7C

Alternative 7D

Alternative 8A

Alternative 8B
   88,620
  121,488

  127,575

  122,759

115,0142-129,9543

172,053 - 173,423

126,779 - 128,149

115,014 - 129,954

 93,258 - 130,359

  122,609
    21,154
    57,010

    60,424

    61,122

 53,2752- 66,P993

109,567 - 113,800

 64,293 - 68,256

 53,275 - 66,099

 29,153 - 64,262

    59,376
NOTES:  XA11 alternatives would produce more energy than would
         be consumed.

        2Assumes trucking maximum distance from treatment
         plants.

        'Assumes trucking minimum distance from treatment
         plants.

SOURCE:  Metro 1983b.
                               72

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     The in-vessel composting method  would not adversely affect
land  uses,  public  health  or   aesthetics of  the  surrounding
vicinity   since   this   method  would  limit   dust,   odor,   and
unsightliness  that could otherwise  affect the area.   The  most
significant  impacts  associated  with tank  composting  at  the
Renton  Treatment   Plant  would  be   energy   consumption,   air
emissions  from the compost facilities, and the  increased truck
traffic resulting  from removal of  composted  sludge.   Projected
energy  requirements   for  the   Taulman-Weiss   composting   are
included in  the energy  production  estimate for  Alternative 2A
presented in Table 3-1.

     After  January  1988,  on-site  composting would  result  in
increases  in  trucking  traffic from the Renton Treatment Plant.
Since  sludge  is  currently  not processed  at  the  Renton Plant,
increases  in  truck traffic  would occur once  sludge  processing
facilities  are  on-line  regardless  of  which  alternative  is
implemented.   Table  3-2  presents  the  projected  truck  traffic
from both the Renton and West Point plants to the year 2000.


West Point Treatment Plant

     Under  all  of  the  project  alternatives,  few  additional
sludge  processing  facilities would be  added  at the  West Point
Treatment  Plant;  one   additional   sludge  thickener  and   one
additional Humboldt dewatering centrifuge would be installed and
housed  within existing  structures  at the plant  (Uchida  pers.
comm.).  Therefore,  no impacts  of  any consequence are  expected
from additional West Point sludge processing.

     Taulman-Weiss  Tank  Composters.   Under Alternative 2A,  6
bioreactors and  2  'cure reactors would be  installed at  the  West
Point  Treatment Plant.   Although no  exact  location for  these
tanks has  been  chosen,  land  is  available  on  the  eastern part of
the treatment plant property (Uchida pers. comm.).

     The construction  and operation  of  the tank  composters  at
West  Point  would  not   adversely   affect  land   uses   in   the
surrounding  vicinity   due   to   the  enclosed  nature   of   the
facilities-.  Trucking  from the  plant  would increase  until 1988,
at which  time truck traffic would  decrease due to start-up of
sludge  processing  facilities   at  the  Renton  Treatment  Plant
(Table  3-2) .  Air  emissions  from  the  Taulman-Weiss system would
be as previously described for the Renton Treatment Plant.


           Impacts of Feasible Long-Range Alternatives

     The  following section  of  the EIS  describes the  existing
environmental  impacts  and mitigation measures associated  with
sludge   transportation,   and   with   five   broad   uses    of
sludge-agricultural     application,    composting,     landfill
                              73

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             Table 3-2.  Projected Truck Traffic From the Renton and
                     West Point Treatment Plants, 1980-2000
                                                        Year
                                1980     1983     1985     1990     1995    2000
Renton Treatment Plant1'2

     Trucks/day                  —       —       —         7        99

     Trucks/year                 —       —       —     2,555    3,285   3,285

West Point Treatment Plant2

     Trucks/day                    7        9       13        8        8       9

     Trucks/year               2,555    3,272    4,794    2,920    2,920   3,285


NOTES:  1Assumes sludge processing on-line in January 1988.

        2Assumes 50 percent of sludge volume each from West Point and Renton
         Treatment Plants after 1988.

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application,  silvicultural application,  and  soil  improvement.
Each  of the  10  feasible  long-range  alternatives  selected  by
Metro fall within one of these categories.


Impacts of No-Action

     EPA  procedures  for  implementing  NEPA  require  that  the
impacts of  a no-action  alternative be  examined in  EISs.   The
no-action  alternative  for this  EIS  relates  to  two  separate
features  of  Metro  planning   effort:    1)   the  long-range  and
near-term  plans,  and   2)  the   proposed  Pilchuck   Tree  Farm
demonstration project.  The analysis below pertains to no-action
for  the  long-range   and  near-term  plans.    No-action  for  the
Pilchuck project will be analyzed later in this chapter.

     The purpose of Metro's sludge management plan and recommended
program   is    to   provide   a    framework   for   initiating
sludge-utilization projects during  the 20-year planning  period.
Metro's preferred long-range   program  does  not  define  specific
projects  but  instead indicates  a  series  of goals  and  actions
that  Metro  could take  to manage  sludge   within  the  20-year
planning period.

     No-action would  essentially  mean  that  Metro would  continue
with  a year-by-year  planning approach  with  no allowance  for
long-term  commitments beyond  3-5 years  to use  of   sludge  for
agricultural application,  composting,  silvicultural  use  or soil
improvement.  No-action  would create  a  situation  whereby Metro
might  not  have  adequate flexibility  and contingencies   in  the
event  established sludge application  sites  could no longer  be
utilized.

     Metro  is  also faced  with a problem of not being able  to
fully  utilize  the King  County  Cedar  Hills  Regional  Landfill.
During  the past  3  years, approximately  49  percent of  Metro
sludge was  applied at that site, however,  indications are that
only  2,000  dry  tons,  or  less  than  6 percent  of  the  1983
projected  quantity of  sludge,  can be  utilized  at that  site
during the current year  (Machno pers. comm.).

     The completion of  an  approved sludge management plan  is  a
requisite  for  DOE approval  of  plans  and  specifications  for
solids  handling  facilities  at  the  Renton  Treatment   Plant.
No-action would mean  that  solids handling  facilities could  not
be  designed  or  constructed,  and  that  Renton  sludge  would
continue  to  be pumped  to the West Point  Treatment Plant  for
processing and disposal.

     Additionally, the  NPDES  permits for  the  West Point  and
Renton treatment plants  require  that  facilities  plans (of which
sludge  management is  a part)  be  completed  for  both  plants.
                                75

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Impacts of Sludge Transportation

     All  feasible  sludge management  alternatives will  require
transporting sludge, in either anaerobic or composted form, from
the Renton and West Point treatment plants.  Table 3-2 indicates
that the number of  trucks leaving  the  two treatment  plants will
increase from 9 per day in 1983 to 18 per day in the  year 2000.

     Table  3-3  presents the  projected annual  fuel  consumption
for sludge trucking for each of the feasible alternatives.

     Under  all  alternatives   (except   2A -  tank  composting) ,
sludge  would  be  transported  from  the treatment  plants  in  30
cubic-yard  leakproof,  open  top   dump  trucks  or   semi-wagon
combination  trucks  with  a  capacity  of  37.5  cubic  yards  of
sludge.   Because of   the  thick  consistency  of   sludge  at  18
percent solids, spills from  the open-topped trucks are unlikely.
The  dump  trucks  are  of  leakproof  design  to  prevent  leakage
around the rear dump gates.

     The haul route from the West Point Treatment  Plant would be
along   the  present  haul   route  through   Discovery   Park  to
Interstate 5,  and then either north or  south to the destination.
The haul  route from the Renton  Treatment Plant would  be along
Monster Road  to  the West  Valley Highway, with  access  to either
Interstate  5  or Interstate  405.   The   small increase  in truck
traffic  caused by  sludge   transportation will not  affect  the
capacities of these road ways.

     Because  specific  reuse  in disposal sites  have  not  been
identified    in    Metro's    long-range   planning,     specific
transportation impacts at these  sites  cannot be evaluated here,
but  would  be  evaluated  in   project-specific   environmental
reviews.

     Table 3-4 presents the air  emissions likely  to  result from
sludge hauling for  each of  the  feasible long-term alternatives.
These  emissions  are  small  compared to regional   mobile  source
emissions.
Agricultural Application

     Description  of  Existing  Environment.   Metro   (1983)  has
definedagriculturallandslocatedfrom35-190 miles  from the
Renton and West Point treatment plants as potential agricultural
sludge application sites.  Agricultural  lands within  this range
may be divided  into  three physiographic  provinces:   Puget Sound
Trough, Okanogan Highlands,  and Columbia Plateau.

     The Puget  Sound  Trough encompasses  those areas  between the
Cascade and  Olympic  mountains  and  is characterized  by  a mild,
wet climate,  with most  of  the precipitation occurring  between
November and May.  The northern portion  of  this region receives
                               76

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                          Table 3-3.  Projected Annual Fuel Consumption for Sludge
                               Trucking for Each Feasible Alternative (gal/yr)
Alternative
      1983
      1990
      2000
1 - Agricultural Application

2 - Composting

7 - Silvicultural Application

7A, 7D

7B, 7C

8 - Soil Improvement

8A

8B

Pilchuck
 65,700 - 277,400

 14,600 -  43,800



 43,800 - 138,700

 29,200 -  65,700



 14,600 - 270,100

109,500 - 138,700

102,200
109,500 - 462,455

 24,455 -  73,000



 73,000 - 231,045

 48,545 - 109,500



 24,455 - 450,045

182,500 - 231,045

170,455
131,400 - 554,800

 29,200 -  87,600



 87,600 - 277,400

 58,400 - 131,400



 29,200 - 540,200

219,000 - 277,400

204,400

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                            Table 3-4.  Air Emissions From Trucking for Each Feasible Alternative
CO
Emissions (Ibs/day)
Alternative
1 -
2 -
7 -

8 -

Agricultural
Application
Ccnposting
Silviculture 1
Application
-7A,7D
-7B,7C
Soil Inprovement
-8A
-8B (WIDOO)
Pilchuck Demonstra-
tion Project
HC
1983
5.3-16.5
1.0-3.0

2.9-9.6
4.4

1.5-15.0
7.6-9.5
6.4
CO
2000 1983
10.7-33.0 16.4-50.5
1.9-6.1 2.7-9.3

5.8-19.1 8.1-28.2
8.8 12.13

3.1-29.9 4.7-45.8
15.1-18.9 23.2-29.0
	 19.8
NOx-
2000 1983 2000
32.7-101.0 23.9-189.4 47.8-378.8
5.4-18.5 8.3-29.7 16.6-59.3

16.2-56.3 25.0-87.6 49.9-175.1
24.26 37.45 74.90

9.5-91.5 9.6-179.8 19.1-359.6
46.3-57.9 74.1-94.0 148.3-187.9
	 70.5 	
              SOURCE:   EPA 198lb;  Metro 1983a.

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40-80 inches of precipitation a year and has  a growing  season  of
150-200  days.   Agricultural soils in  this  northern portion are
concentrated  in the deltas  and  valleys of  Skagit and Nooksack
Rivers  and  were formed on a mixture  of coarse glacial deposits
and  finer-textured alluvial  (river-deposited)  material.   Soils
are  high in organic matter with  CEC  ranging from 10-25 meq/100
grams,  and  pH's   generally  below  6.5  except where   extensive
liming   has    occurred.    Approximately    250,000   acres    of
agricultural land  exist in the northern Puget Sound Trough, with
hay,  alfalfa,  and dairy  being  the  major  uses.   Other  crops
include  various grains, flowers,  and vegetables.

     The  climate  of the  southern Puget Sound  Trough   (south  of
Seattle)  is  slightly  milder than  that  of the  northern  Puget
Sound Trough,  with the growing  season often exceeding  200 days.
Soils  in this  southern region were  not greatly influenced  by
glacial  activity,  but  have  developed  on volcanic or sedimentary
bedrock   and   alluvial    deposits.     Soils   are    generally
fine-textured,  with  low  pH's  (below  6.5)  and  variable  CECs.
Major  crops include silage, barley,  corn,   and peas,  with much
land devoted   to   dairy  production.   Over  300,000   acres   of
.agricultural land  exist in the southern Puget Sound Trough.

     The Okanogan  Highlands  encompasses those areas east of the
Cascades and  north of the Columbia River.  This region is drier
than areas  west   of  the  Cascades,  with  an   average  annual
precipitation  of  about 30 inches and  a growing season of about
120  days.   Soils  are often thin, having  been formed on glacial
deposits and volcanic  outcrops.   Soil pH is  generally above 6.5,
and  the  CEC ranges  from below 5 to near 20 meq/100 grams, except
in  areas where soil  conditioners have been  used.   Major  crops
include  apples, pears, wheat, and barley.

     The  Columbia  Pla'teau includes  the rolling  hills  of  south
central  Washington.   This  area  is  slightly  drier and  warmer
than the  Okanogan  Highlands,   receiving  about   15  inches   of
precipitation  and  having  a  growing  season  of   130-180  days.
Soils   are   underlain   by  volcanic   and  sedimentary  bedrock.
Pockets  of  saline  and  loess  (wind deposited) soils exist in the
eastern  portion of  the  area.   Soil  pH is  usually  high  (above
7.0) and CECs  range from  10-30 meq/100 grams.  Over one million
acres  are  devoted to  agriculture  and  range, with  livestock,
silage, wheat,  barley, apples, and pears as  the major crops.

     Assessment of Impacts.  Alternative  1  consists of applying
3.1  dry tons  of  sludge  per acre  on  agricultural  land to grow
nonhuman food  chain crops  (i.e.,  crops to produce animal feed).
In western Washington  sludge would be  stored in a central 36  MG
capacity  lagoon and applied 8 months  of the  year.   In eastern
Washington, sludge would be stored in 9 lagoons ranging from 3.3
to  4.2  MG  each.   Sludge would  be  applied using  a subsurface
injector system.
                                79

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     Subsurface  Injection System  —  Many potentially  adverse
impacts  would  be  avoided  with  the  use  of  the  subsurface
injection   system.    Because   sludge   would  be   immediately
incorporated  into the  soil,  the  likelihood  of surface  water
contamination  would  be minimized.   Subsurface  injection  would
also minimize  odors  and  allow  for  greater capture  of nitrogen
(normally  lost  by  volatilization  when  sludge  is  applied  on
the surface).

     Agricultural Soils and  Crops —  A number of  physical and
chemical properties of agricultural  soils  would be  changed as a
result of sludge application.  Although the characteristics of
soil  types  vary  widely   in  western  and  eastern Washington,  a
number of potential impacts can be predicted.

     In 1979,  the  EPA  set forth Criteria  for  Classification of
Solid  Waste Disposal Facilities  and Practices;  Final,  Interim
Final  and   Proposed  Regulations  T40  CFR  Part  257) .   In  those
regulationsEPArecognizedthat  "...  land  application  of
parks and forests and reclamation of poor  or  damaged  terrain is
a  desirable   land  management  technique   .   .  . ,"   and  that
"application of solid waste to agricultural lands may also be an
environmentally acceptable method of disposal."

     EPA has established  cadmium to  be  an  important  factor when
sludge is applied  to agricultural land.   During  development of
the  regulations,  EPA  examined  a  wide   range   of   available
scientific  data  associated   with  health  effects  of  cadmium,
maximum cumulative  loadings   of  cadmium assuming a variety  of
"diet  scenarios", annual  cadmium application  limits  and  cadmium
allowances  for growing animal  feed.   Appendix G  of  this  EIS
includes the  entire  text of the disposal regulations  (40  CFR
Part 257).

     EPA  (40  CFR Part   257  1979c)  has  determined  that  the
maintenance of  a soil/sludge pH of 6.5  is  a critical  factor for
land used for production for  either  foodchain  crops or  crops for
animal  feed.    Soils  in  western  Washington  typically have  pH
ranging from 4.5-6.0, and must therefore be limed to  adjust the
soil pH  to  the  necessary 6.5 level.   Metro  proposes to  apply
lime at a rate  of 3  tons  per acre every 3  years on agricultural
soils in western Washington to achieve this pH.

     EPA  (40  CFR Part   257  1979c)  has  also  determined  the
allowable annual cadmium loading rate per acre for production of
leafy vegetable  and  root  crops (0.5 kg/ha or  0.45  Ib/acre)  and
for other food  chain crops (2.0 kg/ha  until June  30,  1984; 1.25
kg/ha  July  1,   1984  to  December 31,  1986; 0.5 kg/ha  beginning
January 1,   1987).  No maximum annual cadmium  loading  rates have
been established  for crops  to produce  animal  feed.   The  basis
for these allowable loading  rates is presented  in Appendix G of
this EIS.
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     Assuming Metro's proposed annual sludge application rate of
3.1 dry tons/acre, the annual cadmium loading rate would be 0.32
kg/ha - well  below the 0.5 kg/ha for the  most restrictive use,
which is  crops  (leafy vegetables and root  crops) .   At the rate
of 0.32 kg/ha/year, sludge could be applied for over 60 years to
agricultural  soils having  a  CEC  greater  than  15 meq/100  kg
before the  allowable  cumulative cadmium application  rate  of 20
kg/ha  was  reached (see  Appendix  B  for  a  discussion of  the
importance of CEC).  On the most restrictive soil (CEC less than
5 meq/100 kg) ,  sludge could be applied  for  15 years before the
cumulative cadmium application rate of  5 kg/ha was  reached (DOE
1982a).

     An application rate of 3.1 dry tons per acre per year would
supply the  equivalent of 98.0 pounds of nitrogen,  considerably
less  than the annual  per  acre nitrogen requirement  for silage
corn  (185 pounds  per acre)  or  orchard  grass (300  pounds  per
acre).  Because the annual  nitrogen requirement for crop growth
would  be  greater  than  the  amount  applied  in  sludge,  the
likelihood of nitrate leaching to groundwater would be very low.
Nearly 6  tons of  sludge  per acre  would  be needed  to meet annual
nitrogen  requirements  for  corn,  and 9.5 tons  per acre would be
needed to meet nitrogen requirements for orchard grass.

     Based  on  EPA regulations  (40  CFR  Part 257 1979c)  the  low
application rate  proposed by Metro would  allow the  land  to  be
used  in  the future for  even the most  restrictive  agricultural
use  (food chain crops - leafy vegetables and root crops) so long
as the cumulative  concentrations  of cadmium  would not exceed 20
kg/ha for a soil  with a  CEC of greater  than 15 meq/100 kg, or 5
kg/ha for a soil with a CEC of less than 5 meq/100 kg.

     The  State  of Washington is in the  process of  revising the
Regulations Relating  to  Minimum Functional  Standards  for  Solid
Waste Handling  (Chapter  173-301  WAC) to be compatible  with  40
CFR  Part  257  and  specifically to address  application  of wastes
to land used for the production of food chain crops  (DOE 1980).

     The impacts of sludge application to agricultural land have
been extensively studied since the early 1970s.  EPA (1976a)  has
indicated that  proper site management is the  key to minimizing
adverse impacts caused by  sludge application.  Close attention
must  be  paid  to  application  rates,  soil  pH,  and the  types  of
crops selected.   In 1977,  Washington  State University conducted
a study of sludge application to agricultural land using 10, 20,
and 40 dry tons of Metro sludge per acre.  Comparisons were made
of heavy  metal  concentrations in  limed and unlimed  soils,  and
silage corn and rye.  Nitrate movements  through the  soil profile
and total and fecal coliform  levels were measured.   In general,
metal  uptake   by  plant   tissues   was  increased   by  sludge
applications,  with rye being  less effective  than  corn in taking
up metals.  Fecal coliform was reduced to less than  1 percent of
initial value in approximately 6 months.
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     Because Metro  does not  plan on  growing crops  for direct
human consumption, sludge applied to the agricultural land would
need only  to be  treated by  a "Process  to  Significantly Reduce
Pathogens"  (e.g., anaerobic  digestion).   In addition,  public
access to the application site must be controlled for 12 months,
and animal grazing must be  prevented for at  least  1  month  (EPA
40 CFR Part 257 1979c).

     As part of any  agricultural  application program, Metro has
defined the following site monitoring features:

     o  One soil  sample per net 200 acres of sludge-applied  land
        with  sampling  every  2   years   for  a   5-year  period
        following last application.
     o  One  surface   water   sample  per  250  gross  acres  with
        samples   taken  monthly   for   2   years   following   last
        application.
     o  One  shallow  groundwater  well per  20 net acres  and one
        deep well per 300 net  acres  with monthly sampling for 1
        year  (shallow well)  and  5  years  (deep  well)  following
        last sludge application.

     Application  of  Metro  sludge to  agricultural  lands  would
result  in  increased trace  metals  concentrations  in  plants,
increases  in  heavy  metals  within  the  soils,  and  elevated
coliform and pathogenic organism levels.   However, environmental
impacts of these  sludge constituents can be  minimized by proper
site management  and   implementation  of  the  mitigation  measures
described below.

     Mitigation Measures.  The impacts of  sludge application to
agricultural land can be minimized by  following  EPA regulations
and guidelines  and Best Management  Practices developed  by DOE
(1982a).   EPA  and  DOE  regulations  and guidelines  should be
used  in  agricultural  application  site   selection,  since  they
reflect current  knowledge  of  the impacts of  agricultural   land
application.

     Prior to application of any sludge,  Metro proposes to:

     1. Develop and  finalize  evaluation criteria  to  determine
        site acceptability-
     2. Develop  an   inventory  of  possible   sludge  agricultural
        application sites.
     3. Evaluate and prioritize sites based on DOE's BMPs.
     4. Initiate a detailed site selection process.

     Because  specific  agricultural  application  sites have not
been  identified  in   Metro's  long-range  planning,  subsequent
site-specific environmental  evaluations  would  be  necessary to
evaluate  site-specific  impacts if  agricultural   application is
implemented.
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Composting

     Description  of   Existing  Environment.    The  composting
alternatives  considered  by Metro  would  require  location  of
facilities at either the  Renton  and West Point treatment plants
or in the Kent Valley industrial area.  The existing environment
of the  Renton Treatment  Plant vicinity  has  been reviewed  in a
previous 1981 EPA EIS.

     The West Point Treatment  Plant is  located on approximately
24 acres  in  north Seattle  on  a  flat, triangular piece  of  land
between Discovery Park  on the  east  and  Puget Sound  on the west.
East of Discovery Park  are  a mixture  of  single and  multifamily,
commercial, and manufacturing uses.

     The Kent Valley  industrial  area includes  heavy  industrial
land uses,  railroad lines,  and  scattered residential  dwelling
units.    Sludge  composting   is  presently  carried  out  in  the
industrial area  by GroCo,  a  subsidiary  of  the  Sawdust Supply
Company.  The GroCo facility  is located  at  the  corner  of  76th
Avenue  South  and  South 202nd Street, 3 miles  north of  downtown
Kent.

     Assessment   of   Impacts.    The  impacts   associated  with
Alternative 2A  (Taulman-Weiss  composting)  at the West Point and
Renton  treatment  plants were previously  discussed under Impacts
of Sludge Processing.  The  following analysis relates to impacts
associated  with  composting operations  of  Alternative   2B  and
distribution of the composted product.

     Air  Emissions  from  Trucking  —  Under  Alternative  2B,
anaerobically-digested  sludge   (18  percent  solids)   would  be
hauled  to a composting  site in the  Kent Valley Industrial Park,
and  either  temporarily  stored  or  immediately mixed  with  a
bulking agent.  The air emissions from trucking are  presented in
Table 3-3.

     Land Use  —  Development  of a 24-acre  composting  facility
would  not  appreciably affect  land  uses   in   the  area  since
composting would  be  compatible with heavy industrial/commercial
uses of the  area.  If  residential  areas were  located  near the
site,  impacts  from  the composting  facility could  result.   In
particular, noise,  light,  and glare  and odors  are  likely  to
result  from the composting activities.

     Surface and  Groundwater  —  Ground and  surface water could
be  potentially  affected  by  runoff  from  the  compost  site.
However, complete paving of the site and development of a runoff
collection system would eliminate  the likelihood of significant
impacts.

     Occupational Health  and Safety  —  Dust and fungal spores
may  be  generated  by   composting   operations,   and  particulate
matter may drift  off-site during high wind conditions.    Public
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health hazards  associated  with composting  involve   four groups
of  pathogens  in  sewage sludge:   viruses,  bacteria,   cysts  of
protozoans,  and  ova  of  helminths.   The  survival  of  these
pathogens  depends  upon   the   treatment   of  sludge  prior  to
composting.  In general, anaerobic digestion has been  shown to
reduce the  concentration  of  detectable viruses, bacteria,  and
protozoa  cysts  by  85-95  percent.   Helminth ova,  however,  are
resistant to anaerobic digestion  (EPA 1979).

     Composting  is  a  thermophilic  (high   temperature)  aerobic
decomposition process.  The heat generated during composting can
both  reduce and  increase  microorganisms,  depending   upon  the
species  type.   Organisms   such  as salmonellae,  total  and  fecal
coliforms  and  fecal streptococci  are  significantly reduced  by
composting   while    thermophilic   microorganisms    such    as
actinomycetes,  murcorales,  and Aspergillus fumigatus proliferate
as a result of the high temperatures (EPA 1981c).

     A  major  public   health   concern   for   compost  workers  in
general  is  exposure  to microbial dusts, when the compost  piles
are  turned  to  maintain  aerobic  conditions.    Direct  bodily
contact with sludge through either the  initial mixing of compost
or the pile turning can expose workers  to pathogens.

     Compost  workers'  exposure  to  aerosols  generated  at  a
composting  site  would be small compared  to  exposure  at  a
wastewater treatment plant.  The  clouds of moisture that emerge
from compost piles  result  from water leaving the sludge matrix
as  gas  and  condensing into  visible  droplets.   This  moisture
should be essentially free of microorganisms and  salts.   Very
little  if  any  information  exists  on aerosol  transport  from
composting sites  (Burge and Millner iji  Bitton et al. 1980).

     The  potential  long-term  health effects on compost workers
exposed  to a  variety  of   fungal  and   bacterial  pathogens  and
toxins of microbial origin  are not well understood.

     Public Health — The  ultimate use  of  the  composted product
has  not  been  established  by  Metro,   and  a   requisite   for
implementation  of this alternative  would  be  to determine  the
marketability of a composted sludge product in the. Seattle area.
DOE  (1982b)  and  EPA  have   identified   static  aerated   pile
composting  as   a  "Process  to  Further Reduce  Pathogens"  (DOE
1982b) ,  a requirement if  sludge  is  likely  to  be used  to  grow
crops for direct human consumption.

     Because   trace   metal   concentrations  are   reduced   by
composting sludge (see Table 3-5), greater flexibility as to the
ultimate  use of the  compost is possible.   The concentration  of
trace metals, particularly cadmium,  would  need  to be determined
to establish allowable uses for the compost.

     Because  a   specific   composting   proposal   has   not   been
identified   in   Metro's   long-range    planning,    subsequent
site-specific environmental  evaluations would  be  necessary  to
evaluate site-specific impacts if composting is  implemented.


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Table 3-5.   Nutrient and Metal Contents of Municipal Sludge and
  Compost.   The Sludge was a 20% Solids Sludge from Seattle.
         The Compost was a 3:1 Sawdust:Sludge Mixture,
                    Composted for 6 Months.
 Nutrient                                      Ratio of Elements
 or Metal               Sludge     Compost       Compost:Sludge


 Nutrients (%)

 Nitrogen                2.30        0.71           0-31
 Phosphorus              1.50        0.51           Q.34
 Potassium               0.16        0.09           0.56
 Calcium                 1.40        0.47           0.34
 Magnesium               0.29        0.09           0.31

 Heavy Metals (ppm)

 Zinc                   2,000         490            .24
 Copper                   900         230            .25
 Lead                     470         220            .46
 Nickel                   170          85            .50
 Cadmium                   40          14            .35
 SOURCE:  Metro n.d.
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     Mitigation Measures.   Any composting site  selected should
be designed  with  impervious  surfaces  and  a  runoff  collection
system connected  to  the municipal  sewer.   Consideration should
be given  to  designing  the  site to  minimize  light,  glare,  and
noise if sensitive receptors are in the vicinity.

     Since the  exposure of workers  to composting  sludge  is of
concern, the following mitigation measures should be considered:

     o  Use of  respirators  or  breathing  masks  in  any enclosed
        dusty areas or high-spore concentration areas.
     o  Sprinkling of site to reduce dust.
     o  Use  of preemployment  health  histories  to  screen  out
        employees  who  would be  at  some  risk  from aspergillus
        inhalation.
     o  Distribution of preemployment  health safety information
        relevant to the compost site environment.
     o  Use of enclosed cabs on composting vehicles.

     DOE  (1982a) has established BMP  for  the processing and use
of composted  sludge.   EPA  is  also in  the  process of drafting
regulations  regarding  the   use  of  compost  products.   Future
regulations may restrict the distribution of composted sludge if
heavy  metal  concentrations   are   too  high  for  gardens  and
foodchain  use.    The  ultimate  use  of composted  sludge  would
conform with these future regulations.

     The   State   of   Washington  has   established   Regulations
Relating   to  Minimum   Functional   Standards  for  Solid  Waste
Handling  (Chapter 173-301 WAC)  which include some provisions for
composting  (WAC  173-301-401   and  WAC  173-301-402).    Relevant
portions of those regulations state the following:

     o  "Materials resulting from composting and offered for use
        by others  shall contain no pathogenic  organisms,  shall
        not reheat upon standing, shall be innocuous ..."
     o  "Byproducts removed  during  processing shall  be handled
        and disposed of in a sanitary and nuisance-free manner."

     To   ensure   that   composting  is  properly  accomplished,
temperature monitoring  should  be continually carried  out during
the  process.   EPA  criteria  (44  CFR  Part  179)  indicate  that
aerated  pile  composting  must  maintain  temperatures  of  131°F
(55°C)  for at least 3 days  to  ensure  that pathogens are further
reduced.

     DOE  (1982a)  recommends  that bulking materials be analyzed
to  ensure suitability  for  mixing  with  sludge.   The  compost
product should also be  monitored to  determine pH, salinity,  and
nitrogen, phosphorous,  PCB,  and heavy metals concentrations.

     Metro should initiate a study to define the potential users
of a composted  product  and  to determine  a likely market in  the
event  regulations   regarding   use   of  compost   become   more
restrictive.
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Silvicultural Application

     Metro  (1983a)  has identified  cost-effective silvicultural
sites  in Washington  as  being  between  30  and  95  miles  from
Metro's  treatment  plants.   Counties within  this  radius include
all  or part  of Grays  Harbor,  King,  Kitsap,  Kittitas,  Mason,
Pierce, Skagit, Snohomish, and Thurston Counties.

     Metro  (1983a) has  recommended  four  alternatives for sludge
application to silvicultural sites:

     Alternative 7A - Public or privately-owned forestlands with
     a Metro-owned demonstration site.

     Alternative 7B - Metro-owned poplar growing forestlands.

     Alternative 1C - Metro-owned multiple use forestlands.

     Alternative  7D -  Public  and privately-owned  forestlands
     with a Metro-owned back-up site.

     Description of Existing Environment

     Geology  and  Soils — The majority  of lands  that  might be
considered  for  silvicultural  use of sludge consist  of  areas of
compacted glacial  till  (a  dense mixture  of gravel,  sand,  and
silt)  underlain by sedimentary bedrock.   A  coarse,  excessively
drained  mixture of gravel,  sand, and  silt known  as  recessional
outwash is  found on top of the denser glacial till.

     Surface  formations vary  widely,  but  areas  in the lowlands
are  likely  to  have  glacial   till,  glacial  outwash or  recent
alluvial deposits  (loosely arranged water-deposited material) at
the  surface.   Soils have  evolved  through the  interactions  of
parent material, time, climate, topography, and biota.

     A large  percentage of western  Washington soils  such as the
Alderwood series have  evolved  on glacial till.   Soils  developed
on  glacial  outwash are  also   very  common.  These soils,  which
include  the  Everett   and  Indianola  series,   are usually  very
coarse   and  have  extremely   rapid   infiltration  rates   and
permeabilities  throughout  the  profile.   Soils  developed  on
alluvial  deposits  are  less  common;  although these soils  vary
widely,  they  are  often poorly drained and found  on low-lying,
nearly level  terrain.

     Silviculture  — The  forests where  sludge  could be applied
are quite varied,  depending on  climate,  soils,  and  distinctive
characteristics.   The  areas  considered  for  sludge  application
can  be  categorized  into vegetative  zones  according   to  their
dominant species.
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     Most forests where  sludge could be  applied  are classified
in the  western hemlock  zone,  which  starts  near sea  level and
extends upward to about the 2,000-foot level.

     Because this zone  is readily accessible, most  of the area
has  been logged  at least  once.   The  most  common species  to
occupy  logged  sites  is  Douglas-fir.    Unlike  hemlock,  this
species  grows  readily  in open areas and has  become  the most
common  species  in the area.   Once established,  the  stands are
often thinned and fertilized before the final harvest.

     Red alder is a  common  species in wet areas and in riparian
sites  in  western Washington,  Western  red cedar often develop
beneath  alder  and  may  eventually dominate  moist  sites.   Four
species, Douglas-fir, hemlock, alder, and cedar,  constitute the
majority  of  trees   in   the western  hemlock  zone.   Scattered
patches of Sitka  spruce,  big leaf  maple,  and  western white pine
also exist throughout the zone.

     Regions above  2,000 feet constitute the silver  fir zone.
This area is wetter and cooler than the adjacent western hemlock
zone.   In  this  zone,   open  sites  are  first   colonized  by
Douglas-fir or noble  fir, giving  way to  silver  fir and western
hemlock once canopy closure has occurred.

     Surface Water — The water resources of  forest areas where
sludge  may  be  applied include a  multitude of  rivers,  streams,
lakes,  springs,  and other  water  bodies.   Outside of  the major
urban areas, surface water  quality is excellent  in  most cases.
Surface  water  supports  a  variety of beneficial  uses  such  as
domestic  and   stock   water  supplies   such  as   irrigation,
recreation;  fish  reproduction, rearing and harvesting;  wildlife
habitat; power generation;  and industrial use  (DOE  1978) .  The
30-95 mile radius from Seattle covers approximately 25  DOE Water
Resource  Inventory  areas  which   include  a  variety of  surface
water bodies of  Class  AA (extraordinary), Class  A  (excellent),
Class B  (good) , and Class C (fair) (DOE 1977) .

     Groundwater — The groundwater resources in the Puget Sound
area  are plentiful and  multifaceted.   In  general,   recharge
occurs  over the entire  area, with water percolating through the
soil  to  the  underlying  water table.    This  groundwater  then
continues to flow through the  soil to a discharge point such as
a  spring,  river, or  the Puget  Sound.    Due  to  the  geological
history of  the  Puget Sound area,   several  aquifers  (soil layers
which can bear groundwater)  have  been created, one on top of the
other,  over much  of  the  area.   These   aquifers are  normally
separated  from each  other  by less  permeable   strata.   Water
percolating  from  the   surface   will recharge  the  uppermost
aquifer,  which   is  generally   perched   above  the   regional
watertable.

     Downward  leakage   from  the  perched   aquifer   generally
recharges the  underlying regional aquifer,   which  in  turn  may
recharge underlying confined aquifers, being  dependent  upon the
head differential between aquifers and the permeability  of the
confining strata.

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     Several  groundwater  and water  resource studies  have been
conducted  which  include  portions  of  the  study area   (Luzier
1969).   Site-specific  groundwater  characteristics  should  be
investigated during project design due  to  the varying nature of
aquifers and groundwater.

     Groundwater  quality  is  good in  most  cases  but can vary
considerably  among  aquifers  and within  aquifers  (Luzier  1969) .
Poor groundwater  quality,  such  as high  salinity  or  high NO, or
high  mineral  concentration,  can  occur  naturally  due   to  the
location of  vegetation  and soil characteristics of the aquifer.
Anthropogenic degradation of  groundwater quality  can also occur
due to land use practices and usage of the aquifers.

     Common  groundwater uses  in the Puget Sound  area are water
supply,  irrigation,  and  industrial  supply.   Groundwater also
serves to maintain stream flow and local springs.

     Wildlife —  The  forest  areas support a tremendous  variety
of vertebrate and invertebrate terrestrial and aquatic wildlife.
Northwestern  coniferous  forests are  a patchwork  of vegetative
cover  types  created  by natural processes or man's  activities,
which  provide  for a diversity of wildlife species.   Many areas
support  rare,   endangered   or  threatened   animal   and  plant
species, and special  biological areas identified  by the USFWS,
the Washington  Department of  Game,  and the Nature Conservancy's
Natural  Heritage  Program.   Many  counties  also have identified
sensitive  or  critical  areas   such   as   wetlands   or  areas
particularly  important  to the  maintenance  of  wildlife  species
(USFWS 1981)  .

     Land Use —  Existing  land uses within  a 45-95  mile radius
from Seattle  consist  of a  variety of urban,  rural, agriculture,
and  forestry uses.   In general, urban  areas  are  concentrated
close  to  Puget  Sound  and  along  Interstate  5   and  405.   An
urban-rural  fringe  containing  a range of uses  from  suburban to
rural  lies  between the urban areas along Puget  Sound  and  the
rural   areas   near  the   Cascade   and    Olympic   Mountains.
Agricultural   activities   occur   in  the   bottom   lands  and
floodplains of the area's major rivers.  Much of the  land in the
Cascade and Olympic Mountain ranges is used  for forests.

     Land  use  planning   and  control  in  the   area   is  the
responsibility  of the counties  and local municipalities, with
planning coordination provided  by  regional  planning  agencies.
Major  regulations  and policies  covering land uses are  found in
comprehensive  county  and  municipal  plans,   zoning  ordinances,
subdivision  ordinances,  shoreline  master   programs,   subarea
plans, and comprehensive water and sewer plans.

     Assessment of Impacts.   The following discussion of impacts
associated with sludge application  on  forestlands  provides  a
broad  overview  of potential impacts  in the Puget  Sound area.  A
detailed impact analysis  of  the Pilchuck  demonstration  project
follows.
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     Geology  and  Soils  —  Geologic  features  are  important
considerations  for  sludge application because  they  control the
movement   of   groundwater   and   influence   soil   properties.
According  to  the  DOE  (1982a),   areas  considered  for  sludge
application should not have parent material which is excessively
drained.   In  areas where  bedrock is  present,  it should  be at
least  3  or 4  feet  below the  soil surface.  Bedrock  should be
free   from  coarse  conducting   layers   or   conduits.    These
guidelines  would  eliminate  the   following  land   areas  as
potential sludge application sites:

     o  Mountain regions with shallow soils.
     o  Areas with excessively drained parent materials, such as
        those underlain by coarse glacial outwash.

     Construction activities  associated  with  sludge application
to  forest  sites  would  include   sludge  basin  excavation  and
construction  of skid  roads  to gain  access to  the  site.   These
activities would  have  no major impact on the  geology  of forest
sites  in western Washington.

     Sludge  should  not  be  applied to soils  that possess  high
antecedent heavy  metal or  nitrogen  levels  due to  the possible
contamination of groundwater if it is used for water supply.

     The  DOE  recommends  that the  average  surface  slope  of
forested  land  receiving  sludge  not exceed 20-30 percent   (DOE
1982a) .   Slopes up to  40  percent  may  be utilized if  the slope
length is short.

     These  recommendations  greatly  limit  the amount of  land
suitable  for sludge application.   Most of the mountain areas are
too  steep or have thin  soils.   Many of the  low-lying areas in
the  Puget Sound basin  possess soils with  fine  surface textures
or water  tables close to the surface.

     The  suitability of a soil for sludge application depends on
the  physical,  chemical,  and  mineralogical  properties  of  the
soil.  Physical properties may be the most important of these.

     Soil texture determines the rate of soil water movement and
sludge  decomposition.   Coarse surface  soils  are desirable for
sludge application because  of  their  high infiltration  rates and
limited potential for  surface  runoff and  erosion.   A finer soil
texture below  the surface  layer  is  desirable  to prevent rapid
movement  of  infiltrating water to the groundwater.  Clay soils
should be avoided to decrease the possibility of surface runoff.
Ideally,  soils  should  be  deep  (greater than 3  feet)  and possess
an impermeable  layer at the 3- to 5-foot depth  (DOE 1982a).  The
water  table  should be  below  5 feet or  be  absent,  and  soil pH
should be  above 6.5  to limit the  movement  of  heavy  metals into
the  groundwater  (DOE   1982a).   Soils which contain  significant
amounts of organic matter in their surface layers will  also help
arrest heavy metal movement  (Appendix B).
                               90

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     Lagoon and  skid  road  construction impacts may include soil
compaction,  top  soil removal,  and  increased  erosion.   These
impacts  are  likely  to be  most significant  on soils  that  are
shallow,  organic,  fine  textured,  located  on  steep  slopes,  or
possess impermeable layers close to the surface.

     Soil  compaction  would occur wherever  vehicles move across
undisturbed   soil.    Compaction    can   result   in   reduced
infiltration,  increased  runoff, and  a reduced availability of
oxygen  to plant  roots.   Wet  soils  or soils  with a  high clay
content   are  especially   vulnerable   to  compaction.   Topsoil
removal for road construction  may  severely decrease future site
productivity;  this impact  would be  most significant  on  sites
with  gravelly  soils  which  have a  limited  amount  of organic
material.

     Some  soil  erosion can be expected because of the exposure
of  bare  soil  during  construction.    Because  potential  sludge
application sites  are  generally  not  steep,  soil loss should not
be  widespread.   Soils with  coarse  upper horizons  underlain by
layers with restricted drainage are most susceptible to erosion.

     Silviculture  --  Forest   species  vary  widely  in  their
response  to  sludge application.  Variables  controlling species
response  include  stand age,  sludge  application rate and timing,
and site productivity.

     Table  3-6   shows  the  overall  suitability of  species  for
sludge  application.   High  mortality  of  hemlock and  red  cedar
seedlings  has been observed on  sludge-treated  sites  (Henry  and
Cole  1983.) .   Metro  (1982)  has recommended  that sludge not  be
applied  to stands under  4  feet  in  height  or  those  within  10
years of  harvest.  Although  older stands  (50  + years)  may react
favorably  to  sludge  application, recent  research  suggests that
the greatest growth responses may be realized by applying sludge
to  stands  between  the ages of 5 and  30 years growing on poorer
quality  sites   (Henry  and  Cole 1983).   Sludge application  to
species   which   fix   nitrogen,  such  as   red   alder,   is  not
recommended due  to the potential for  increased nitrate leaching
(DOE   1982a).     This  would   be   a  particularly   important
consideration if the site is used as a drinking water supply.

     In summary,  silvicultural  application  of sludge is subject
to  certain constraints based on geology,  soils, topography,  and
tree species and age.  Other constraints concern the maintenance
of  buffer zones  around  water bodies  and  dwellings.   Due  to
constraints,  not all forestland is appropriate  for silvicultural
sludge application.

     King  County,  for example,  contains  approximately 867,000
acres  of  forestland.   Approximately  17   percent  of  this  is
Wilderness Area,  which  by  law  is  not  available for  sludge
application  (U.   S.   Department  of  Agriculture   1978).    An
additional 29 percent is located within municipal watersheds.
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                Table  3-6.  Species Suitability Classes
Site Condition
                                            Species Selection
                         Best
                   Adequate   Unsuitable
Recently cleared  sites




Young plantations

Existing forests
Cottonwood
Poplar
Douglas-fir
Sitka spruce
Host conifers
 ines      Western hemlock
           Redcedar
           Red alder
Pines      Red alder

Pines      Red alder and
           roost other
           deciduous species
SOURCE:  DOE 1982a
                                      92

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     Assuming Wilderness Areas  and  watersheds  are excluded from
consideration, approximately  477,000 acres remain  as potential
silvicultural disposal  sites.   The  exact  portion of  this land
not  suitable  for sludge application due to  such environmental
constraints as soils and slopes,  is not known.  Metro, however,
has  estimated that  for  the  silvicultural  sludge  application
alternative requiring public or private land (Alternative A), 70
percent of the area considered would be unsuitable due to buffer
zones, slopes, sensitive soils,  and roads  (Metro 1983a).   Based
on   this   assumption,   approximately  143,000   acres  would  be
potentially suitable for use under  Alternative 7A.   This  figure
is considerably  larger  than the 41,100 acres  Metro  projects it
may  need to accommodate 100 percent of  the  sludge produced from
1990-2000  using   land  owned by agencies  or  companies  in  the
timber  management business.   Only  approximately 20,000  acres
would  be  needed  if  2   inches  of sludge were  applied per acre
rather than 1 inch.

     Construction-related impacts on the  silvicultural resource
would  be   caused by  removal   of  land  from  forest  production.
These  impacts would  vary,  depending  on the  quantity of skid
roads to be constructed, the size of the  lagoon and surrounding
facilities,  and  the quality  of  stands that  would  have  to  be
removed.

     Surface  Water  —  Specific  impacts  of  a  silvicultural
application of sludge on surface water are dependent on the site
location.   A  complete  investigation is necessary for  each site
before  application  occurs.   This  investigation  should  include
the    determination     of    the    following     surface    water
characteristics:

     o  location of streams, tributaries,  and lakes
     o  location of wetlands and flood plains
     o  hydrological data
     o  water quality data
     o  existing and possible future uses

Other  factors which  also are  important for a  complete  surface
water  impact  assessment include:   topography,  groundwater flow
and quality, and soil characteristics.

     Types of possible impacts on surface water are:

     o  nutrient enrichment
     o  decrease in water quality
     o  contamination of water supply
     o  decrease in quality of stream habitat
                              93

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Nitrogen and phosphorous  are  the  most common limiting nutrients
in  a  water  body.   Both  are  added   to  the  forest  environment
during a sludge application and, if allowed to a water body, may
result  in  some  of the  above-listed  impacts.   Nitrogen  is  of
special concern due to the ease at which nitrate travels through
the  forest  environment.   Other  sludge  constituents,   such  as
heavy metals and pathogens, may also result in the above-listed
impacts if allowed to enter the surface waters.

     Groundwater — Groundwater impacts would  result  if sludge
constituents were  to  migrate  from  the ground  surface  to the
underlying   water   table.    Such   migration  could   decrease
groundwater quality, which could impact an existing use, such as
a  water supply.   The  determination  of  impacts  is  therefore
dependent  on  specific  site  characteristics,  local  uses,  and
project details.   Leaching of  nitrate  is most likely  to occur
due to  the large  quantity  of newly-available nitrogen  and the
ease  of  nitrate migration  in  a soil  column.   Possible impacts
from nitrates are:

     o  health hazard to water supplies
     o  nutrient   enrichment  of   surface   water   bodies  which
        receive groundwater flow

     Land  Use.   The  application of sludge  to forestlands would
not change existing land uses on the application sites or in the
surrounding  area  in   the  short   run.   The  effect  of  sludge
application  on future  land uses  is  uncertain  and depends  on
specific  uses   likely  to  be  proposed  for  sludge  application
sites.   Certain   land  uses  such  as  agricultural  food  crop
production  could   be  precluded  in  the future  because  of  high
concentrations  of  heavy  metals  and  organic  compounds  in  the
soil.

     Mitigation  Measures.    Mitigation  measures  to   control
erosion, compaction,  and  topsoil removal  are generally similar
for all potential  sludge  application sites;  these  measures are
discussed  in the  Pilchuck  project  impact assessment  later  in
this  chapter.    Additional  site-specific  measures  should  be
developed on a case-by-case basis.

     Surface Water —   Care  should be  taken  in  the  project
design to prevent  adverse impacts to surface waters.  A complete
investigation of the water  resources  associated with  a proposed
site is necessary  to allow  for  inclusion  of possible  mitigation
measures.    Once the  resources  have  been established,  buffer
(nonapplication) zones,  application  rates  and  timing,  facility
locations,  and other project features can be modified to provide
sufficient protection to surface waters.

     Verification of the actual application process is necessary
to ensure that the designed mitigation measures are carried out.
Training  of sludge  application  personnel would  decrease  the
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possibility  of  an   accidental   application  of  sludge  in  a
designated  nonapplication  area.    A  surface  water  monitoring
program carried out before,  during,  and after after application
is necessary  to establish  the  impact  of  sludge constitutents.
If, during  application,  a  significant surface  water  impact is
detected  by   the  monitoring,   corrective  measures   can   be
implemented.

     For  planning  and  cost  comparison  purposes,  Metro  has
assumed and included in  project  cost  estimates,  the  following
monitoring  features for  any interim or full-scale silvicultural
application project:

     o  One soil sample per 200 net acres of sludge-applied Land
        with  sampling  every  2   years  for  a  5-year  period
        following last application.
     o  One  surface  water  sample  per 250  gross  acres  with
        samples  taken  monthly   for  2  years  following  last
        application.
     o  One shallow  groundwater  well  per  20 net acres  and  one
        deep well per 300 acres with monthly sampling for 1 year
        (shallow well)  and 5 years (deep well)  following last
        sludge application.
     o  One plant tissue/growth response monitoring site per 200
        net acres with remeasurement every 2 years.

     The   actual   monitoring  program  necessary   for   each
silvicultural  application  site  would  depend on  site-specific
factors such as proximity  of the  application area to a drinking
water source,  existing groundwater quality, proximity to surface
waters, type of soil and the soil CEC as well as other features.

     Groundwater —  A detailed understanding of the groundwater
conditions  and uses  associated  with   a  proposed project  site
should be  incorporated into  project design.  This  would allow
for measures to be  taken  before a problem  occurs in an aquifer.
Preventive measures which should be considered are:

     o  modify application rate
     o  modify application schedule
     o  modify application areas

     Land Use — An adequate  buffer zone surrounding the sludge
application sites  should  be provided  to protect area  residents
and land uses from possible adverse impacts.
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Soil Improvement


     Description  of  Existing Conditions.   Metro   (1983a)  has
defined potential  soil improvement  sites located  10-180  miles
from the Renton and West Point treatment plants.  Potential soil
improvement  sites  could include:   surface mines,  gravel  pits,
landfills,  and  powerline   rights-of-way.    During  excavation
activities  surface  soils  of  surface  mines,   gravel  pits  and
landfills are  often removed, exposing  coarse  mineral  subsoils.
Surface soils  of  powerline  rights-of-way  are  usually  disturbed
but generally not removed.

     Surface  Mines —  In   1979,  there  were   approximately  170
surface  mines  within  the   area  being  considered  for  sludge
disposal   (McFarland   et    al.   1980).   These   mines   cover
approximately  4,500   acres   and   consist  mainly   of  basalt,
andesite,  clay, and coal mines in  western Washington.

     The WIDCO  surface coal mine near  Centralia  is one of  the
largest surface mines  in the state.  By  1982,  a  total of  3,300
acres had been mined.   Since 1978 Metro  has been  hauling sludge
to  the  WIDCO site  for  use  as a soil improvement.   During 1982
Metro was under  contract to provide approximately  22,000  wt of
sludge  to  storage  lagoons  at  the  WIDCO  site.    Sludge  is
temporarily  stored and  then  applied  at  two   different  rates;
15  tons per  acre  per year  on subsoils and 50  tons  per acre  for
surface   soils.    Metro  sludge  is   used  only   for  topsoil
improvement  for eventual  forest  crop  production.   Sludge  is
applied through  soil  injection 8-16  inches deep on  300  acres
annually.    A  grass   cover   crop   and   eventually   Douglas-fir
seedlings are planted on the reclaimed soil.

     Sludge delivered  to the WIDCO site by  Metro  is  stored in
existing  storage   lagoons  at  several  locations  on  the  WIDCO
property.   WIDCO personnel  transfer sludge to  a modified 4-wheel
drive application  vehicle  with a  5,300-gallon capacity  sludge
storage.   The vehicle applies  sludge   approximately  2-3  feet
below the soil surface through a subsurface injection system.

     The  use of  sludge for land  reclamation at  WIDCO  is  an
ongoing activity permitted  by Lewis and Thurston Counties.   Both
counties  have  approved the proposed   facilities,   application
methods, application  rates  and monitoring programs  for  the  use
of  sludge.  WIDCO  has  completed the  environmental checklist  and
both the Lewis County  Health District and Thurston  County  Human
Services Department have made declarations of  nonsignificance as
defined under RCW 43.21C.030(2) (c) .

     A  hydrologic   and soils  monitoring  program is  currently
carried out by WIDCO.   Groundwater  wells below each application
area  are  sampled  and  analyzed   monthly for  nutrients  and
bacteria,   and semi-annually for  heavy  metals and  persistent
organics (WIDCO 1982a; 1982b).  Results of the  sampling are sent
to the county and DOE each  month.
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     The  WIDCO  soil  improvement  program  has  been  approved by
Lewis  and Thurston  Counties.   Permits  are  issued  yearly,  and
Thurston  and  Lewis  Counties and DOE  receive  monthly monitoring
reports.  WIDCO  is  to release  its five-year operation  plan in
1983, along with a  more  general plan  for operations to the year
2015 (Hickey pers.  comm.).

     Based on  contacts with  nine  cities  and municipalities in
the  vicinity  of the  WIDCO  site,   only  two,  Olympia  and Metro,
have plans  for  using WIDCO  for sludge application  in  the near
future  (Kolby; Barkman; Price; Batterby; McCartny; Hyde; Layman;
Thorn;   Hynes  pers.   comm.) .   The , City  of   Olympia   has  an
approximate 15-  year agreement with  WIDCO  to  provide  6.5  dry
tons  of  sludge  daily,   or  approximately 24  percent  of  the
calculated sludge need by WIDCO (Kolby; Hickey pers. comm.).

     Sand and  Gravel Pits  --  In  1979  there  were approximately
400  sand and  gravel  pits   within the  10-180  mile radius  of
Seattle  (McFarland  et  al. 1980).   Pit size varies considerably,
but  the average size  is approximately  5  acres.   Approximately
2,000   total  acres  of  gravel  pits  are  located  in  western
Washington.

     Landfills  —  Landfill   sites  in  the  immediate  King County
area  include  the  Cedar  Hills  (920 acres),  Duvall  and Midway
landfills.  Sludge  from  Metro treatment plants has  in  the past
been used as top dressing at Cedar Hills and Duvall.

     Rights-of-way  —  Within the  10-180 mile radius  of Seattle
are  approximately   70,000  acres  of transmission  rights-of-way
operated  by  the BPA.   Other  rights-of-way  in   the area  are
maintained by Puget Power Company and Seattle City Light.

     Assessment of  Impacts.   Metro has  identified two potential
soil improvement alternatives - Alternative 8A,  Soil Improvement
of Public or  Private Land and  Alternative 8B,  Soil Improvement
at WIDCO.  Sludge would  be  stored  in  either  lagoons in  the Kent
Valley  (Alternative 8A) or at storage lagoons at WIDCO.

     Application  of  sludge   for   soil  improvement  would  be
oriented  toward providing,  an  additional  organic, and  nutrient
content  to  mineral subsoils  or soils  affected by construction
activities.    The  objective  would be  to  provide  a  medium  for
rapid  growth  of  vegetation  to  stabilize   soils  that  would
otherwise be susceptible to erosion.

     The  use   of   sludge  on  surface-mined   lands   could  be
considered a valuable asset  for any program  of  site vegetation.
The  State of  Washington rules and  regulations   pertaining  to
protection and  restoration   of  lands  disturbed through  surface
mining  state that "Revegetation shall be  required only  where it
                               97

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is   appropriate   to   the   intended   subsequent   use   of  the
surface-mined site, or where, on a temporary basis, it is needed
to provide  soil stability,  to prevent  erosion,  or  to  provide
screening" (Board of Natural Resources 1970) .

     The federal Surface Mining and  Control and Reclamation Act
of 1977  (30 CFR  Section  700)  requires rehabilitation of surface
mines throughout the United States.  One specific section of the
Act  entitled  Nutrients and  Soil  Amendment  (Section  715.16 2D)
would  be  particularly  pertinent  to  the use  of   sludge  for
rehabilitation  of  surface  mining sites.   That section states
that nutrients  and soil amendment,  in amounts and  analyses as
determined by soil tests, should  be  applied to the surface soil
layer  so  that  it   will   support  postmining  land  uses  and
requirements of site revegetation.

     Storage  Lagoons   —  For  Alternative  8A,  storage  lagoons
would  need  to  be  constructed  at a location  central  to  soil
improvement sites.   The selected  site would need  to be situated
in an  area  remote from  possible  incompatible land  uses  (e.g.,
residential, commercial or recreational uses)  and sensitive odor
receptors.    The  DOE's   BMP   identify   lagoon   design   and
construction  considerations  needed   to  achieve  proper  sludge
handling and management.

     For   Alternative   8B    or    for   alternatives   involving
application  of  sludge  as   a landfill  top  dressing,  lagoons
provided  by  the soil  improvement site  or landfill  owners and
operators would be utilized as storage areas by Metro.

     Site Selection -- Selection of sites for sludge application
under  Alternative  8A  would  require  Metro to  follow its  plan
implementation process previously described in Chapter 2 of this
EIS.  According to DOE (1982a), critical  factors  to consider in
site selection  include groundwater  and surface water systems,
background  water   quality,   geology,  site   physiography  and
topography,  physical  and  chemical properties  of  surface soils,
and  surrounding land uses.

     Sludge Application Rates —  Metro would  need  to determine
the  likely  vegetation to be  grown on the  site and  whether the
vegetation would be used as  animal feed,  for human consumption,
or   for  nonfood-chain  uses  (e.g.,   timber  production).   EPA
(1979c)  and  DOE  (1982a)  have established  allowable  heavy metal
loading  requirements per acre for  land  to  be  used  to grow crops
for  direct  human consumption.  In addition, if crops are to be
grown as feed for animals whose products are consumed by humans,
pH adjustments  equal  to  or greater  than  6.5  would be required.
Analyses  of allowable cadmium loading  were  presented  in the
Agricultural Application  section  of this  EIS  and will  not be
repeated here.
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     At   the   present  time  no   regulations  apply  regarding
allowable  heavy metal  loading  for nonfood  chain uses  on soil
improvement sites  or when sludge is used  as  a top dressing for
landfills.  Loading  rates  have  been established by such factors
as  annual nitrogen  requirements  to  grow the  vegetative  cover
(e.g.,  ryegrass,  fescue  or  Douglas-fir  seedlings)  or  best
estimates  of what  quantities  of sludge could be applied without
causing   environmental   problems   (e.g.,   significant  nitrate
backing or phytotoxicity).

     Land  Use  — One of  the  more  important  considerations for
soil  improvement would be the compatibility  of the proposed
sludge application  activity with surrounding  land uses.   While
most surface mines,  gravel pits,  and  landfills are likely to be
situated  in an  area  where  surrounding land uses are compatible,
many  powerline  rights-of-way lie  immediately  adjacent  to high
density residential  and commercial uses.

     One  other  consideration  is that of  future use  of the soil
improvement  sites  once  sludge  application has  been   completed.
Since soil improvement  sites  often  have high sludge application
rates  (.e.g. ,  15-50  dry tons  per acre) ,  some  future  land uses
(specifically the use of the  site  for growing food chain crops)
may  be  precluded.   If  sites  were to eventually  be used  for
residential  development,   some  restrictions  of  use  may  be
necessary  (i.e., backyard  gardening).

     Compatiblity with  Site Activities — Any sludge utilization
activities on  lands used  for other purposes  would  need  to  be
compatible with the  primary  uses.   For  example, sludge  would
need to be supplied for gravel pit or  surface mine  restoration
so  that  adequate  time  would be  allowed for  vegetation  growth
following  application.    Additionally,   the   use   of   sludge  on
powerline  rights-of-way   may   have  an  effect  on  vegetation
management carried  out  by the  power  companies, and the use  of
sludge at  landfill sites could interfere with primary day-to-day
activities.

     Monitoring   --  For   Alternative   8A,   Metro   would   be
responsible for  soil and water site monitoring.   As  a minimum,
DOE  (1982a) recommends  that,  based  on site-specific  conditions,
"Surface  water  that  flows  from a sludge-treated  area  should  be
sampled  above  and  below  the  point  it mixes with  receiving
streams.    Groundwaters   should  be  monitored   from  wells  both
up-gradient  and down-gradient  from the  sludge  treated  areas.
Soil  samples   should be   taken  from   sludge  application  sites
before applying  sludge  and again  after the  total maximum safe
sludge applications have been made."

     Sites to be used for  soil improvement would be subjected to
the SEPA  process, and an environmental  checklist and/or  and EIS,
would be prepared by Metro as needed.
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     Mitigation  Measures.   The  DOE  Best Management  Practices
(1982aTprovidesomegeneral  guidance   for  proper   site
evaluation, management and monitoring.  Measures specific to the
requirements of  each  proposed soil improvement  site would  be a
necessary part of any EISs prepared for those projects.

     Because of  the concern for  future  uses  of soil improvement
sites the following mitigation is suggested:

     o  Future   property   owners  should  be  notified  by   a
        stipulation in  the land  record or property deed  which
        states  that  the property has  received  sludge  at  high
        cadmium  application  rates  and  that  food chain  crops
        should not be, grown, due to a possible health hazard.
     o  Metro should  keep  an  accurate  record  of the  locations,
        dates of application,  quantities and  quality  of sludge
        applied on all soil improvement sites utilized.


              Economic Impacts of Metro's Preferred
                     Long-Range Alternatives

     Metro has  identified  its  recommended  plan as a combination
of  the four  broad sludge  management  categories  (agricultural
application,  composting,   silvicultural application,  and  soil
improvement) previously analyzed in this  chapter.  The  impacts
associated  with  sludge  processing,  hauling,  sludge  storage
application  and monitoring  for   each  category  were  considered
previously in this chapter, and will not be restated here.
User Rates

     One  feature of  the  plan  not  analyzed  in  the  previous
discussions was costs of the Draft Sludge Management Plan to the
user within  Metro's  service  area.   Funding  for  the costs  of
construction  and  operation   and   maintenance   of  the   sludge
processing  and  application program  would  be  provided  by  a
combination  of  federal  and  state construction  grants,  local
revenue bonds, and monthly sewer service fees.

     For  approved  capital   facilities,   for  which  funding  is
available,  federal  grants  can  pay  up  to  75  percent  of  the
eligible cost, state grants  up to 15 percent,  and local funds 10
percent.   If  the  project   is  classified  as   innovative  and
alternative by  the  EPA,  the  federal grant  can  increase  to  85
percent, the state grant becomes 9  percent, and  the local share
decreases  to  6 percent.  In  the  past,  Metro  has  sold  revenue
bonds to finance the local  share of the  capital  costs, and then
repaid these bonds using a portion of the Metro monthly charge.
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     Annual  operation and  maintenance  costs  are  paid  for  by
Metro,  and   no   grant  funds  are   involved.    Operation  and
maintenance  costs are  paid  for  by  a portion  of  the  monthly
charge collected by Metro.  The 1983 monthly base rate is $5.85.

     For    purposes    of    the    Sludge   Management    Plan,
Metro determined  a year 1990  total  base monthly  rate  of $3.20
per customer  for  construction and operation and maintenance of
in-plant sludge processing  at Renton  and West  Point,  and costs
associated with  sludge hauling, .storage application,  and  site
monitoring.   The   estimated  split  of  costs  for  in-plant  and
sludge management  (application) would be as follows:

     o  In-plant costs (67.2 percent) - $2.15
     o  Sludge hauling and ultimate disposition  (32.8 percent)  -
        $1.05

     The base monthly rate of  $3.20  is an  average and would
vary,  depending  on  the  sludge  disposition category  selected.
Table  3-7  presents the range of total  base monthly rates  for
each category-  The total year 1990 Metro monthly sewer rate per
customer would be  approximately  $15  per  month,  depending on the
category finally chosen.


                Impacts of Metro's Near-Term Plan

     Metro's near-term plan will consist of a five-year plan and
a one-year plan.   The five-year plan has not  yet been  prepared
and therefore  is  not  evaluated in the Draft EIS.   According to
Metro, the  final   facilities  plan,  to be  completed in  June  or
July 1983,  would specifically identify anticipated strategies to
meet the five-year planning goals of  sludge disposition:  soil
improvement,  35 percent;  composting,  25  percent;  silviculture,
25  percent;  and  agriculture,  15 percent  (Metro letter  to  DOE
1982b).   The  Final  EIS  will  evaluate  the   impacts   of  the
five-year plan.

     Metro's 1983  plan (one-year plan) would include use of five
sludge  application  sites   for which  permits  currently  exist
(WIDCO,  Pack  Forest,   GroCo,  and  Cedar  Hills   and  Duvall
landfills);  the Pilchuck  Tree  Farm  (permits in  progress) ;  and
other sites  not  yet  identified.   The impacts  of  operations  at
the permitted  sites are  not evaluated in this  EIS  because  SEPA
requirements   (environmental   checklists   and/or  environmental
impact  statements) have  been  previously  met  and because  no
federal funding is proposed  for  continued operations  at these
sites.  Documents  associated with past environmental analyses of
those sites  are  available  for review at Metro's Environmental
Planning  Division.    An    impact   analysis  of   the   Pilchuck
demonstration project immediately follows this  section.
                               101

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      Table  3-7.   Projected  Monthly  Base Rates for the
     Long-Range  Sludge Management  Alternative (Year 1990)
Management Alternative                      Monthly Base Rate


Agricultural  application                    $2.42  to $2.98

Composting                                  $3.02  to $3.15

-Silvicultural application                   $2.63  to $3.60

Soil  improvement                            $2.22  to $2.90


SOURCE:  Metro  1983a.
                               102

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              Impact Analysis of the Pilchuck Tree
                   Farm Demonstration Project
Introduction
     The following  impact  analysis is based  on the description
of the Pilchuck Tree  Farm  sludge demonstration project prepared
by Metro (1982) and briefly  presented  in Chapter 2 of this EIS.
The proposed  sludge  application sites are  shown in Figure 3-1.
A  detailed description  of  the  proposed  demonstration  project
appears  as an appendix to Metro's, Sludge Management Plan.

     This  impact analysis  consists  of  evaluations of impacts of
a  no-action   alternative,   construction-related  impacts,  and
operation-related impacts.


Impacts of No-Action

     Metro and the Pacific Denkmann Company (Pilchuck Tree Farm)
have a cooperative interest in the sludge demonstration project.
The demonstration project  would allow Metro  to  continue  with a
program of sludge  application on  forest  lands  and specifically
to:  1)  provide  the public  with a better  understanding  of the
benefits  and  impacts  associated  with  sludge   application,  2)
determine  tree growth  response on a managed  forest,  3)  conduct
intensive  site  monitoring,   and  4)   land-apply  a  portion  of
Metro's  1983  sludge  volume.   Also,  the  project would  allow
Pacific  Denkmann to  analyze  the  effectiveness  of  sludge  in
improving  timber production on a portion of the Armstrong tract.

     A  no-action  alternative  would  mean  that  none  of  the
aforementioned  project  objectives  would  be  achieved.   Metro
would need to secure capacity for disposal of 8,000 wt of sludge
elsewhere  and might  have  to  initiate  use  of  another  forest
demonstration site.
Construction-Related Impacts

     Few facilities would be required for Metro and the Pilchuck
Tree Farm  to conduct  the  sludge demonstration  project.   Metro
has identified 4  storage alternatives  (1  MG storage basin, 0.25
MG "basin, reusable  tank  and a trailer)  and access  roads  as the
only construction features of  the  proposed action.   Table 3-8
presents the  construction-related impacts  associated  with each
storage alternative and the access roads.
                                103

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               Sludge
             Application
               Areas
          Sludge Handling
              Area
                                 SOURCE: METR0.19B2d
                 FIGURE 3-1
       Proposed Sludge Application
            Sites and Facilities,
Pilchuck  Tree  Farm, Arlington, Washington
                     104

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                       Table  3-8.  Construction-Related Impacts of Storage and Access Road Construction
                                                     Pilchuck Tree Farm
       Impacts
                        1 mg
                        Lagoon
                                         Storage Alternatives
0.25 mg
Lagoon
Reusable
Tank
                                                        Trailer
Access
Roads
Mitigation Measures
o
Ul
Clearing, grading,
 soil removal and
 disposal
Erosion

Soil compaction


Potential -runoff to
 surface water

Vegetation loss

Wildlife habitat
 loss
Noise
        Light and glare
        Recreational uses
Aesthetics

Construction-related
 employment
                                  0
                                  0
                                 N/A
   0
   0
                                    N/A
              N/A
             N/A
                        0
                        0
                                                                    N/A
                                         Disposal of spoil material in a manner
                                         to avoid impairment of surface water
                                         bodies.
                                         Construction activities only during dry
                                         months.
                                         Use of low pressure tires on construc-
                                         tion vehicles.
                                         Construction activities only during dry
                                         months.   Use of straw bales and silt
                                         screens on any slope areas.
         Construction during late summer or early
         fall to avoid nesting birds.

         Use of noise control devices on con-
         struction equipment; construction car-
         ried out only during daylight hours.

         Construction carried out only during
         daylight hours.

         Portions of the site would be closed to
         recreational uses; warning signs on
         roads leading to construction site.

         None needed - site will be isolated from
         sensitive receptors.
       NOTES:   + = beneficial  impact; x =  severe adverse impact; 0 = moderate impact; - = minor impact; N/A - no -impact.

-------
Geology and Soils

     Description of Existing Environment.

     Geology --   The  surface geologic  and  topographic features
of the  Pilchuck  site  are the result of  a  series of glaciations
that  began  about  one  million  years  ago.    The most  recent of
these  glaciations,  the  Fraser,   occurred   between  10,000  and
25,000 years ago.   In  addition to shaping  the  land,  the Fraser
glaciation deposited thick layers of sand,  gravel, and silt over
the sedimentary bedrock.

     As  the  glacier  advanced,  it  overrode  the soil  and  rock
mixture it was pushing, forming a dense layer known as compacted
glacial  till.   This   material   varies  from  20-150   feet  in
thickness and underlies the Armstrong tract of the Pilchuck Tree
Farm.

     Meltwater streams, active as the glacier began its retreat,
are   responsible   for   the  deposition  of   a   poorly  sorted,
excessively drained mixture  of sand,  silt  and  gravel  known as
the Vashon Recessional  Outwash.   This  layer varies in  thickness
from 15-200 feet and was deposited on top of the glacial till.

     The geology  of  the remaining areas of  the Armstrong tract
is dominated by  the  actions  of the Stillaguamish  River.   Thick
alluvial  (water-formed)  deposits of  coarse   sand  and  gravel
intermixed with  silt  and  clay  underlie much of  the  southeast
side of the Armstrong tract (Figure 3-2).

     The two sites selected for the first applications  of sludge
are underlain  by  a mixture of recessional  outwash,  Vashon  till
and  alluvial  material  (Figure  3-2).   The  northern site  lies
within the Vashon recessional outwash,  whereas the southern site
contains outwash in the northern portion, with till and alluvium
in the southern half.

     Soils  —    In soils  investigations  conducted  by  Metro,
Ragnar  and Winston soil series were  identified on  the  project
site.  Most of the Armstrong tract is  underlain by Ragnar soils
which are  deep,  well  drained,  and  formed  on  glacial  outwash.
This  fine  sandy  loam has  moderately  rapid permeability  in  the
top 2-3  feet and  rapid permeability  in the  loamy  sand  and  sand
that exists below the surface soil.  Permeability  is defined as
"a quality of  a  soil  that allows  air and water  to move through
it" (SCS 1937).

     The Winston series is similar to  the Ragnar but the subsoil
contains more  gravel.   The  surface  soil  (to about 35  inches)
consists of  a  loam and  silt  loam  of  moderate  permeability.
Below   this,   an  extremely   gravelly  sand   of  very   rapid
permeability  extends to a depth of over 60  inches.
                              106

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              FIGURE  3-  2
    Geologic   Features
  of  the  Pilchuck   Site
                                                          r=legend:
                                                                          SOURCE: METRO 1983d
                                                                  M.UOQC HAHOLINQ SITE


                                                                  DCMOMSTMATION SITES


                                                                  ALLUVIUM


                                                                  VASHON TILL


                                                                  SEDIMENTARY BEDMOCK


                                                                  VASHON RECESSIONAL OUTWASH
                                                                   STILLAQUAMISH SAND  MEMBER

                                                                  VASHON RECESSIONAL OUTWASH
                                                                   SAND AND GRAVEL
                                               107

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     Soils   on   the   Pilchuck   site   are   similar   to  other
glacially-derived western  Washington with  respect  to chemistry
and nutrient movement.   Soils  on the site  are  strongly acidic,
with  an average  pH  of  about  5.3   (see  Appendix  C) .   Surface
layers  are  the  most acidic, reflecting the  high organic matter
content of  the  upper  horizons.   Soils  become  less acidic with
depth.

     Productivity  on  the  Pilchuck  site  is   limited  by  the
availability of usable nitrogen  (Staringer pers.  comm.).   The
vast  majority   of  nitrogen in  forest  soils  exists  as  organic
nitrogen, which is  not usable by  plants.   Organic nitrogen must
be converted to mineral  nitr.ogen  to become available to plants.
Appendix B contains the results of laboratory analyses performed
on soils  from  the  Pilchuck site.  Based  on these results, none
of the cations or metals tested appears to be present in amounts
that would cause a deficiency or toxic reaction  in tree species.

     Soils  loss from the Pilchuck  site  is limited by  the high
infiltration  rates  of  the soils,  gentle  slopes,  and  heavy
vegetative   cover.    Surface   erosion   requires   that   the
infiltration  rate   of the  soil  be  exceeded   by  the  rainfall
intensity,  thereby  causing  surface ' runoff.   This runoff  must
then encounter and detach soil particles.

     Soil   series   present   on   the  demonstration  site  have
infiltration  rates  exceeding  the  majority of  local  rainfall
intensities, restricting the possibility of surface runoff (Soil
Conservation Service  1937,  1973) .   Tree  farm employees consider
surface runoff  insignificant from  the  two  demonstration sites
(Staringer  pers.  comm.).   The  Winston soils   (north  site)  are
more likely  to  produce surface  runoff due  to the finer texture
of the  surface  soils.  Slopes on  these  areas,  however, are less
than  six percent,  thus  reducing  the  possibility of  surface
runoff.

     Mass movement  of soil  from  the  demonstration  sites  is
highly  unlikely because  of the  gently  sloping  terrain.   Small
slumps have occurred  along  the steep banks  of Rock Creek, north
of the two sites.

     Soil physical  properties  such as  texture, structure  and
aggregate  stability  also   influence  erosion.    Coarse-textured
soils such  as Ragnar  possess  a  low aggregate stability  and  are
nearly  structureless.   These   factors  make   the  soil  more
susceptible   to   erosion.   Although  the  finer   texture  of  the
Winston soils encourages surface runoff,  it also promotes higher
aggregate stability  and  the  formation  of  an  erosion-resistent
structure.
                               108

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     Soil microorganisms  are responsible  for  the decomposition
of organic matter (including nitrogen transformations), transfer
of nutrients  to the plant  root tips,  incorporation  of organic
material,  and  improvement  of  soil  aeration.   Most  of  the
activity takes place within  10  centimeters of  the soil surface,
and increases near root tips.

     Soil organisms include  microflora  such as fungi, algae and
actinomycetes,   and   microfauna    which   include   protozoa,
Collembola, Acarina, and Nematoda.  Bacteria are also present in
forest soils.  The microflora, especially  fungi, are responsible
for the degradation of humus and  the translocation of nutrients
to the root  hair of higher  plants.   Microfauna consume detritus
and humus, but  lack the enzymes for  significant  degradation of
this  material.   Bacteria   perform  a   number  of  functions,
including  the  transformation  of  organic  nitrogen  into  forms
usable by  forest plants.   In acidic  forest  soils  fungi are the
dominant group  of  microorganisms  (Miller in  Sopper  and  Kardos
1973) .   In  western Washington  soils,   microfauna are  limited
mainly to  Collembola  (springtails)  and Acarina  (mites)  (Mayer
1980).   Although  bacteria  are vital to  many soil  processes,
their numbers are limited by the high carbon to nitrogen ratio,
acidic conditions and low temperatures of area soils  (Trappe and
Bollen in Heilman et al. 1979).  Their low numbers are partially
responsible  for the buildup  of organic  nitrogen and the paucity
of usable mineral nitrogen.

     Assessment of Impacts.

     Geology -- There  should be no  operation-related  impacts to
the geologic features of the area.

     Soils — Digested, dewatered sludge possesses physical and
chemical properties which are significantly different from those
of forest  soils.  In  the  forest,  sludge  is  initially viewed as
an anaerobic  layer  of organic  material with  high  pH,  nutrient
and metal content,  low carbon to nitrogen  (c/n) ratio and a high
waterholding and cation exchange capacity.

     The   impacts   of  sludge  application  on   the  physical
properties of forest soil have received some study,.  Immediately
upon deposition, sludge  may cause  a temporary lowering  of the
soil's infiltration rate due to surface sealing (Kirkham 1974).
This condition would be most prevalent where  large trees  and a
minimum  of  undergrowth allow  a more even coverage  by sludge.
Due to the relatively  small  amount  of sludge applied, roughness
of the forest floor, cracking  of  the drying sludge and the high
antecedent permeabilities of Winston and Ragnar soils, decreases
in soil  infiltration  rates  on the  demonstration  sites  would be
slight and temporary (Henry pers.  comm.).
                              109

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     Sludge  application  is  known  to  improve  soil  structure,
aggregation and  texture,  especially on sites with  coarse soils
(Epstein 1973) .   This  results  from the great number  of organic
particles  present  in  sludge.    Improvements   in   these  soil
properties    will   increase    water    and    nutrient-holding
capabilities, erosion resistance, and drought resistance.

     Additional  impacts to  the physical  properties of  the soil
would  result  from  the  movements  of  the  sludge  application
vehicle through  the  forest.  Surface  soil areas traveled by the
vehicle would be compacted, resulting  in  lowered  infiltration
rates,   reduced   porosity   and   possible   surface   ponding.
Compaction would be greatest  on wet soils  and on those areas
which  have not  been  exposed  to vehicle  traffic  in the past.
These  areas  would include the southern  half of the  north site
and the majority of the south site.

     Digested  dewatered  sludge  contains  large  amounts   of
nutrients  and heavy metals  as compared  to forest  soils  (Table
3-9).   These  characteristics   are  responsible  not  only  for
potential  increases in  tree growth, but  also for the  alteration
of a number of soil chemical properties and processes  including:

     o  pH
     o  CEC
     o  mechanisms for cation movement
     o  nitrogen cycling
     o  heavy metal concentration and movement
     o  concentrations of organic toxins

     A  brief  summary of  potential  impacts of  those  factors  is
presented  here,  but  the reader should consult  Appendix  B for a
complete discussion.

     Sludge   pH   is   considerably  higher  than  that   of  the
demonstration    sites'    soils     (Table   3-9).     Upon   sludge
application,  surface soil pH  increases  in response to  the more
alkaline sludge.  As decomposition proceeds, however,  sludge and
soil pH declines and may reach  values below that of the original
soil before returning to background levels (Edmonds and Mayer in
Bledsoe 1981) .

     The  CEC  is the  ability  of  a soil  to adsorb  positively
charged   ions   (cations) .    Because   sludge   contains   large
quantities of negatively  charged  organic colloids,  the  CEC  is
significantly  greater  than  that  of  coniferous  forest  soil
(Zasoski pers. comm.).  As  these organics are  incorporated into
the  soil,  the   soil's   ability  to   bond  positively  charged
nutrients and metals would increase (Edmonds and Cole  1977) .

     Sludge application dramatically increases the concentration
of cations in the  soil.   Although many  of these are adsorbed in
the upper  soil  horizons or  utilized by vegetation, some may be
subject to leaching.   To move through  the soil,  these  cations
                               110

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     Table 3-9.  Comparison of Chemical Characteristics
        of the Pilchuck Tree Farm Soil and West Point
                 Digested, Dewatered Sludge
                                 Sludge                Soil*
pH                                  7.4                5.3

Nutrient Levels
(% of dry weight)

Organic-N                           3.4                0.31
Total P                             1.5                0.26
Total K                             0.15               0.054

Metals  (mg/kg)
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
PCB (mg/kg)
46.0
390.0
1,160.0
720.0
6.2
155.0
1,780.0
1.6
1.6
40.0
13.0
21.0
.22
45.0
59.0
N.D.
NOTES:  * Soil values taken from Metro sampling 5/82-7/82
          (see Table  - ) .

        Complete digestion used for heavy metal determinations

        N.D. = none detected.

SOURCE:  Metro 1983d.
                              Ill

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must bond with a negatively charged particle or anion.  Nitrogen
transformations   following   sludge  application   (Appendix  B,
nitrogen cycling) may produce  the  mobile  anion nitrate in large
enough quantities  to facilitate the  loss of  some of the added
cations.

     Alteration  of  the  forest's  nitrogen  cycling  capabilities
is  one  of  the  major  impacts  of  sludge  application.   Sludge
application is likely to result in the following:

     o   increased vegetative uptake
     o   increased nitrate leaching
     o   increases loss of gaseous nitrogen
     o   increased soil storage of nitrogen

     Sludge application would also increase the concentration of
heavy metals  in  the  soil.   Metals  added  to soils through sludge
application may succumb to the following fates:

     o   vegetative uptake
     o   bonding by organic polymers in the upper soil horizons
     o   bonding by metal oxides throughout the soil profile

     The  trace metals  to  be  added  to the soil would  include
those  listed  in Table  3-10.  Extensive research has  shown  that
the majority  of metals  are bound  in  the  upper  soil  layers and
seldom move into the mineral soil or groundwater (Henry and Cole
1983;  Williams  et  al. 1980).   Other  considerations  such  as
groundwater and  surface runoff are evaluated  elsewhere  in  this
EIS.

     Organic  toxins  including pesticides  and  herbicides may be
added  to the  soil when  sludge  is  applied.  Although the exact
fate of  these materials is not  known, the mobility  within the
soil is  greatly  restricted  due to  their  low solubility in water
(Darce  i^n  Bitton et  al. 1980) .   Humic substances found in the
soil's   organic   surface  layer  adsorb   the   toxins  readily,
preventing  their  movement  into   plants   or   through the  soil
profile  (Bailey and White 1970; Lichtenstein 1971).   Adsorbed to
the   soil   organic   layer,   the   toxins    are   subject   to
volatilization,  and  photochemical  and microbial decomposition.
The  high  organic   matter  content  of   soils  on   the   two
demonstration  sites  should  help prevent  significant  movement of
these toxins within the system.

     Sludge provides  a  sediment source that   is exposed to the
erosive  forces  of   rain  and  surface  runoff.  Because  sludge
possesses  unique  physical  characteristics,   it  reacts  quite
differently to these erosive forces than does  a layer of applied
soil.   The  high  organic matter  content  of   sludge  acts  as  a
binder,  holding  sludge particles  together.   Sludge  contains
about  27 percent organic carbon  (a  measure of  organic  matter)
compared to about 5 percent for the surface of glacially-derived
soils  (Mayer 1980).  Even if sludge particles  became detached, a
mechanism for  transport is still  needed.   It is unlikely  that
surface  runoff capable of transporting detached sludge particles

                                112

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could  develop  on   the   nearly   level,   porous  soils  of  the
demonstration sites  (see  Soil Impacts,  Physical  Properties and
Soil Existing Conditions,  Erosion).

     Mass  movement   (e.g.,  slumps,  slides)  of  sludge  is  also
unlikely, provided sludge is applied only to the relatively flat
demonstration sites.  Tilting  table  experiments have shown that
1 inch of  sludge  applied  to a forest floor resisted movement on
slopes up  to 42  percent  (Henry  pers.  comm.).   Slopes  on the
demonstration sites do not exceed 10 percent.

     The following two properties of sludge are important to the
microbiological resources of the soil:

     o  high pH
     o  low carbon/nitrogen ratio

In  areas  where  sludge  can be  applied uniformly  (older stands
having  a  minimum of  ground  vegetation)  temporary,  anaerobic
conditions may  facilitate a short-term drop in the populations
of  soil organisms.   In  the freshly applied sludge,  bacteria are
the dominant life form, with  almost  no  fungi present (Miller _in
Sopper and Kardos 1973).   Although  initial  colonization of the
sludge by  fungi  is  slow,  the most  significant  decomposition of
the sludge would take place in the first month  (Edmonds and Cole
1980) .

     As  litterfall  and nitrogen  removal  combine  to  raise the
carbon/nitrogen  ratio  and  lower   the  pH  of  the  decomposing
sludge,  fungi  will  begin to  invade  the sludge.   Mayer (1980)
found  that  3  months  after  application  aerobic  conditions
dominated  the  sludge applied  under  a forest canopy.    After  6
months, sludge fungi and Collembola populations reached those of
unsludged  control plots.    By 12  months,  fungi populations  in
sludge soils were higher than those of the control  (Mayer 1980).

     Microbial  populations at  the  Pilchuck  sites   may  require
less time  to  invade the  sludge because  of the reduced  rate of
sludge  application   compared  to  the   studies  cited   above.
Populations of microorganisms should remain high for a number of
years due  to  the  increased organic matter added by the  sludge,
as well as that furnished by the increased growth and litterfall
of  vegetation  (Mayer 1980) .  Edmonds and  Cole  (1980)  estimated
that 2 inches of sludge would require 33 years  for 99 percent of
the organic matter to decompose.   Faster rates  of organic matter
decomposition may  be  expected  on  the  Pilchuck   site  due  to
smaller application rates and increased amounts of rainfall.

     Displacement  of  soil   microorganisms  by  sludge-induced
organisms  is  highly  unlikely.  Competition  for microsites  is
fierce and the  organisms  present  in sludge  are not well suited
to  long-term survival  in  the hostile  soil  environment  (Edmonds
and Cole 1980).
                               113

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     Mitigation Measures.

     o  Skid roads used to transport and  apply  sludge should be
        designed  to  alleviate   possible  ponding  of  water  or
        concentration  of  surface  runoff  in  areas  close  to
        streams or other surface water.
     o  Monitoring  of  sludge   should  be  conducted  to  ensure
        proper  percentages  of   water,  nutrients,  metals,  and
        organisms.   This  would  help  ensure  that  sludge  would
        react as expected after it was  applied.
     o  Sludge  application  vehicle routes  should be  carefully
        selected  to  minimize the travel  of  the vehicle  in the
        forest.   This  would help  prevent soil  damage  such  as
        compaction.
     o  Sludge  should  not be applied  to  soils  wherever larger
        areas  of  the organic layer may  have been disturbed  or
        removed.  This  would reduce  the  possibility of  rapid
        movement  of  heavy metals or other contaminants  through
        the soil profile.
     o  Accurate  and  visible   flagging  of  demonstration  area
        boundaries to ensure that sludge is not  applied to areas
        unsuited  for coverage.    This  should help ensure  that
        sludge will  not be  applied to  areas with  steep  slopes,
        shallow soils, or high ground water levels.
     o  Refraining  from  applying  sludge  during  a heavy  rain.
        This would reduce soil damage by the  application  vehicle
        and  lower  the  risk  of  groundwater  contamination  and
        surface runoff.
Air Quality

     Description of  Existing  Environment.   Ambient  air  quality
in the  Arlington  area is  considered  excellent.  The  area  lies
within   the   air   quality  attainment   areas   for   suspended
particulates,   carbon  monoxide,   and  photochemical   oxidants
(ozone).

     The DOE  has  maintained ozone  monitoring at  the  Arlington
Fire  District  No.   22  Station  and  a  suspended  particulates
station  at  Lake  Stevens   (PSAPCA  1981).   Ozone  concentrations
have been below the National and Washington State ozone standard
of 0.12 ppm (DOE 1982c).

     Slash burning  in forested areas  often causes  smoky  haze.
Odors from farming operations often dominate the area.

     Assessment of  Impacts.   Depending  on  the  sludge  storage
alternative  selected,  the  sludge  application  project  would
require  between  365  and  520  truck  trips  to  haul  8,000 wt  of
sludge to the site.   Each  haul day, haul trucks  would  emit  from
2.8-6.4  pounds  of hydrocarbon  (HC) ,  9.2-19.8 pounds  of carbon
monoxide  (CO),  and   31.2-70.2  pounds of  nitrous  oxide  (NO )
during  transport  from the West  Point Treatment  Plant to  tlie
Pilchuck Tree Farm.   The  number of  haul  days would range  from
66-104,  depending on alternative storage.


                              114

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     The removal of sludge from the storage area and application
to the  sites  would require  the  use of a  diesel  powered sludge
pump,  nurse   vehicle   and  application   vehicle   which  would
contribute  minor  HC,  CO,  and NO   emissions  to  the  local  air
                                 x
basin.

     Emissions  from the  haul trucks  and  sludge  pump  will  be
relatively  minor  compared  to  regional emissions,  and  are  not
expected  to  significantly  affect   ambient  air  quality.   The
emissions would  be generated  for  the duration of  the trucking
and application of sludge  (approximately one year).

     The  impacts  of  odors  are  presented  in  the  Aesthetics
section of this evaluation.
Surface Water

     Description of Existing  Environment.   The near-term sludge
demonstration site at the Pilchuck Tree Farm is bounded on three
sides  by  streams;   Rock  Creek   flows  along  the  northeastern
boundary, Kunze Creek flows along the  western  boundary,  and the
North  Fork   of  the   Stillaguamish   River   flows   along   the
southeastern boundary (see Figure 3-3).  No other streams or wet
areas are located within the demonstration area.

     Rock Creek and  Kunze Creek are both  approximately  5 miles
long and drain  approximately  825  and  1,350 acres, respectively.
They flow generally southeast and discharge to the North Fork of
the  Stillaguamish.   Neither  creek has  been  gaged,  but  their
flows have been estimated to vary  between 1  and 90  cubic  feet
per  second   (cfs)   (Metro  1983d).    The   North  Fork  of  the
Stillaguamish River  is  approximately  50  miles  long  and  drains
over 262  square miles  upstream  of  the  demonstration site.   A
U. S.  Geological  Survey   (USGS)   gaging   station   is  located
approximately  2 miles  upstream  from the demonstration  site.
Fifty years of flow data show an average flow of 1,891 cfs (USGS
1981).    Table  3-11  summarizes  the hydrological data of  these
three streams.

     Water quality data on the North Fork of  the. Stillaguamish
River have been collected by the USGS and DOE.   The station is 3
miles  upstream  from   the  flow   gaging   station.    Metro  has
summarized some of these  data in  Table 3-6 of  the Demonstration
Sludge Application  Project Report  (Metro 1983d).    A  complete
summary of water quality data for the North Fork Stillaguamish
is presented  in Appendix F.  Water quality data on  Rock Creek
and Kunze Creek have  been collected by Metro  and are presented
in Table  3-12   (Metro 1983d).   Existing  water quality for  both
creeks is within the  State of Washington  surface water  quality
standards for Class  A  (excellent) water bodies  (see  Appendix F
for those standards).
                               115

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          FIGURE 3-3
Surface Water Resources of the
 Pilchuck Demonstration  Project
     Arlington, Washington
              116

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   Table 3-10.   Projected Loadings  of Heavy Metals per Hectare,  Pilchuck
                          Demonstration Project1
TRACE METAL
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
HEAVY METAL CONCENTRATIONS
IN METRO SLUDGE
(mg/kg) 1
14.0
46.0
390.0
1,160.0
720.0
6.2
155.0
1,780.0
KILOGRAMS /HECTARE
(kg/ha) 2
0.6
2.2
18.4
54.6
34.4
0.3
7.3
83.8
POUNDS /ACRE
(Ibs/acre) 2
0.5
2.0
16.6
49.1
31.0
0.3
6.6
75.4
1  See Table 2-3  for more  detailed  description  of  heavy metal  concentrations
  in the Metro sludge.

2  Based on application  rate  of  1 inch  of  sludge per  acre.
                                   117

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                    Table  3-11.   Hydrologic  Data  for  Rock  Creek,  Kunze  Creek,  and
                                  North  Fork  of  the  Stillaguamish  River
CD

Length, miles
Drainage area, sq. mi.
Average flow, cfs
Average annual discharge
Discharge to
Maximum flow, cfs
Minimum flow, cfs
Rock Ck.
5
1
1-90*
UK
N. Fork
UK
UK
Kunze Ck.
5
2
1-90*
UK
N. Fork
UK
UK
North Fork
Stillaguamish
50
2922
1,891
1,370,0002
Port Susan
30,6002
1172
          NOTES:  UK = unknown.
                  *  = estimated range of  flows
                  1from WDOR Stream Catalog.
                  2from USGS 1981.

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               Table 3-12.  Water Quality Data  for  Pock Creek and Kunze Creek
                             (Sampled March, May, June,  July 1982)
Rock Creek
Conventional
Parameters
NH -N
NO +NO -N
Total P
Total K
pH
Turbidity
Conductivity
Metals
Cadmium
Chromium
Copper
Mercury
Nickel
Lead
Zinc
Bacteria (Geometric
Total Coliform
Fecal Coliform
Fecal Streptococci

Unit
mg/1
mg/1
mg/1
mg/1




mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
means)
MPN/100 ml
MPN/100 ml
MPN/100 ml
Mean
(n = 7)
.014
1.12
.027
0.93
7.3
0.82
52

—
<.012
.0016
<.0002
.012
.02
<.006

310
38
240

Minimum
.002
0.93
.013
0.34
6.8
0.3
39

<.oooia
<.001
.0014
<.0002
.0004
<.02
<.006

49
11
36

Maximum
.029
1.36
.035
1.27
7.5
1.6
69

.0019
.02
.0021
.0003
.02
.03
.025

3,300
230
490
Mean
(n = 7)
.021
1.01
.030
1.01
7.2
1.5
55

<.0001
<.011
.0017
<.0002
.0097
.03
<.006

260
66
440
Kunze Creek

Minimum
.009
0.65
.014
0.53
6.7
0.5
44

—
<.001
- .0016
<.0002
" .0011
<.02
<.006

31
8
130

Maximum
.032
1.83
.043
1.33
7.5
2.8
70

<.0001
.03
.0019
.0003
.033
.05
<.006

1,300
2,200
1,300
NOTES:  Viruses not analyzed until pumps can be installed  (September 1982).
        Parasites not detected in four samples tested  (two Rock Creek and two Kunze Creek)
        Chlorinated Organics not detected in four samples tested  (two Rock Creek and two
          Kunze Creek).
        Salmonella and Yersinia were isolated from Kunze Creek in one sample each.
  <    =  Less than
  MPN  =  Most Probable Number

SOURCE:  Metro  1983d.

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     The North  Fork  of the Stillaguamish  has  been designated a
shoreline  of  statewide  significance  and  a  Class  A (excellent
water quality)  stream.   Rock  Creek and  Kunze  Creek should also
meet Class  A  water quality criteria  due to their discharge to
the North Fork of the Stillaguamish River.  Appendix F lists the
state of Washington's Water  Quality  Standards  for  each water
quality class.

     Beneficial   uses   of  the   Stillaguamish   River    include
irrigation,   domestic   water   supply,   stock  water    supply,
fisheries,  recreation, and  limited  navigation  (Snohomish County
Planning Department 1974) .  Rock  Creek  and Kunze Creek have the
beneficial uses of fisheries and possible recreation.

     Assessment  of  Impacts.  Impacts  of sludge  application on
surface water resources and water quality could occur if:

     o  Sludge   is  either  directly   sprayed   or  accidentally
        spilled   into   the   three   streams   bordering   the
        demonstration sites.
     o  Contaminated surface  runoff from  the  application sites
        flows into the streams.
     o  Sludge  was  carried into  streams  as  a  result  of  soil
        erosion.
     o  Groundwater   contamination   led   to   surface   water
        contamination.

     Metro  has  designated minimum  100-foot  buffer zones between
the  application  areas  and  the  three  streams   bordering  the
demonstration  sites.   Metro  has   also  established  a   25-foot
sludge  application  setback  from the edge  of bluffs surrounding
both  sites.   The actual  horizontal distances  from application
areas  to  the  edge  of the  three  streams  would  range  from  .a
minimum  of  180  feet (near  the north  site)  to a maximum of 415
feet  (south site near Rock Creek).

     The  possibility  of  sludge  being  sprayed into  the buffer
zone  or   streams  would  depend  upon  the   distance   of  the
application road  from  the edge  of the  bluff and the competence
of  the   application  vehicle  operator.   In  the unlikely event
sludge  were distributed  onto  the slopes within  a  stream buffer
zone  it  would be unlikely to  move downslope any great distance.
Research  at Pack Forest  showed  that sludge  applied up  to 1.6
inches  thick  remains stable on  forested slopes up to 42 percent
(Henry and  Cole  1983).  Stream bank slopes  on  the site are less
than 40 percent  (USGS topographic quadrangle).

     Under a worst-case situation sludge could conceivably enter
Kunze Creek in  the  event  the  application or  nursing  vehicles
spilled  sludge  on or  near the bridge crossing from the storage
lagoon  to  the application  areas.   If  sludge were  to  enter the
creek, the  impact would depend on  the  amount of sludge spilled,
the  rate  of  entry  into  the  creek,  the  stream  flow,  and
                              120

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such factors  as  BOD (biochemical oxygen demand)  of  the sludge.
Sludge would  probably be  carried downstream and enter the North
Fork  Stillaguamish, where  dilution  would occur.   Substantial
dilution  of  any  sludge  entering  the North  Fork Stillaguamish
would occur before  reaching the  City  of Marysville public water
diversion 5.5 miles west of the project site.

     Contamination  of  surface  runoff  would occur  if  sludge
constituents dissolve or are suspended in water as it flows over
the  application  sites  and  enters the  streams.   Due  to  soil
characteristics  at the  sites,  very  little  over-the-land  flow
occurs, with  the  majority  of  precipitation percolating  into the
soils.   Therefore, surface  runoff, would  only  be expected  to
occur  during  large  storm events,  which would  also result  in
larger  stream flows.   Any  impacts would  be  decreased by  this
additional  dilution  and  overshadowed  by  natural  pollutant
increases during such a storm event.

     An analysis  of soil  erosion potential is described  in the
Soils  and Geology portion of  this  evaluation.   The  possibility
of groundwater contamination leading to subsequent contamination
of surface water  is discussed in  the following  portion of this-
evaluation.

     In  its  draft  Pilchuck Tree Farm report, Metro  identified
the  proposed  site  contaminant  monitoring  for  the  application
sites   (Table  3-13).   The  monitoring  program  would  include
monthly  pre-  and  postsludge  application  monitoring  for  the
parameters listed in  Table 3-14  for  Rock  and Kunze  Creeks and.
two  springs  located to the east  and  to the  west  of  south site
(Figure 3-4).

     In  the   event monitoring of surface  water  indicated  the
presence  of  a  parameter  in  excess  of  stream water  quality
standards (Appendix F) , Metro  would cease  sludge application in
the  area where   limits  were  exceeded   and   collect  additional
samples on a  high priority basis.  Based on  the  results  of the
further testing,  Metro would  consider the  following alternative
actions:

     1. Provide  water supply  protection  if  any- water  supply
        wells may be affected.

     2. Revise   application    plan   by  altering  either   the
        application  rate,  season  of   application,   areas  to
        receive applications, or a combination of these.

     3. Proceed   as  planned  with  upgraded   monitoring   for
        contaminant movement.

     4. Continue   with  original   application   plan  if   the
        evaluation  indicates no  significant  increase  in risk of
        affecting   an  aquifer   used  for   water  supply  Metro
        (1983d).
                               121

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         Table 3-13.   Pilchuck Tree Farm Preliminary Soil and Water
                         Quality Monitoring Program*
     Sampling
     Station
       Type
 No.  of
Stations
   Parameter Groups and Sampling Frequency
   Group 1        Group 2     	Group 3
Primary Wells & Spring

  Test wells  & Spring   3

  Neighbors wells        4

Lysimeters and
Secondary Wells

  Old stand              5

  Young stand           13
  Well 13                1

Springs                  2
Streams                  4

Soil and Sludgeold stand 4
             young stand 4

Lagoon Leakage Sump
and Monitoring Well

Background Wells         9
              B&A Monthly

             3 4/year
              A I/year
               L Quarterly

               B Monthly
               A 4/year
             B & A Bi-Monthly
BSA Monthly

B&A Bimonthly
B&A Bimonthly
              B&A Bimonthly
                              Quarterly
                              Quarterly
B Monthly
A Twice monthly
F Weekly
L Quarterly

B Bi-Monthly
A Twice monthly
F Weekly
L Quarterly

L Quarterly
                                            B&A&L Monthly
3
 Group 1 is all parameters
 Group 2 is all conventional parameters,  metals,  and  indicator bacteria
 (coliform and streptococci) - indicator  parameters.
 Group 3 is pH, EC, NO  and NO ,  and  orthophosphate - tracer parameters.
v\
 Selected secondary wells and springs will  be  monitored bimonthly  for bacteria
 and metals before application to establish background conditions

Legend:
 B indicates frequency before sludge  application  - background monitoring
 A indicates frequency after sludge application - to  continue for  12 months
   after application
 F indicates during first flush of water  moving through the soil profile
 L indicates long-term followup - for period from end of  first year to end of
   fifth year after application for wells and  end of  third year for all other
   stations

SOURCE:  Metro  1983d.

NOTE:  Subject to change depending on field conditions.

                                       122

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     Table 3-14.
Metro Contaminant Monitoring Project -
       Parameters
Conventional Physical and
   Chemical Parameters

Organic N  (Kjeldahl)
   (sludge/soil only)
NH.-N

N02+N0~

N0~

Total P
Orthophosphate P
Total solids
Volatile solids
pH
Turbidity
Conductivity
Fluoride

 Organic Toxicants

Aldrin
Arochlor  (PCB's)
Chlordane
DDT  (4, 4'-DDT,DDD & DDE)
Dieldrin
Endrin
Lindane
Methoxychlor
Toxaphene
2, 4-D
2, 4, 5-TP  (Silvex)

	Parasites	.

Ascaris lumbricoides
Giardia lamblia
Others as identified in sludge
                         Metals
                      Arsenic
                      Barium
                      Cadmium
                      Chromium
                      Copper
                      Lead
                      Mercury
                      Nickel
                      Selenium
                      Silver
                      Zinc
                      Potassium'
                             Bacteria
                      Salmonella
                      Shigella
                      Yersinia enterocolitica
                      Mycobacteria
                      Fecal Coliform
                      Total Coliform
                      Fecal Streptococci

                      	Virus	

                      Total enteric viruses
                      Polioviruses
                      Coxackieviruses B
                      Echoviruses
                      Coxackieviruses A
                      Adenoviruses
                      Reoviruses
 A nutrient analyzed with metals,
SOURCE:  Metro  1983d.
                              123

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         FIGURE 3-4
Surface and Groundwater
   Monitoring  Stations,
Pilchuck Tree  Monitoring
          Project
                                 legend
                                       SOURCE: METRO. 1983d
• NOME*

•I STORAGE BASIN

• MONITORING WELL

* PIEZOMETERS

O SHALLOW OROUNDWATER
   MONITOMINQ WELL
A SURFACE WATCH SAMPLING
   STATIONS
* SOIL/SLUDGE MONITOMINQ
   STATIONS
                          124

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     The  DOE's BMP   (1982a)  recommend  surface  water  sampling
upstream  and  downstream  of  the  application  site.   Metro's
proposed  program  would include  such  a  sampling  regime.   Since
monthly  sampling  will  be  done  prior  to  and  after  sludge
application for a wide range of parameters, Metro should be able
to react quickly to any indication of contamination.

     Mitigation Measures.

     o  Slight adjustments  in  the  25-foot-wide  buffer zone from
        the edge of the bluff  to the  application  area should be
        made to ensure that a minimum horizontal distance of 200
        feet is maintained.
     o  Where  possible the application  road network  should  be
        placed no  closer  than 150 feet from the  edge  of  the
        cliff-edge buffer  zone.   This would  ensure  that sludge
        could not be sprayed into the buffer zone.
     o  Wherever the application road network is closer than 150
        feet from the  edge  of  the  buffer zones,  high-visibility
        markers  should  be  placed   along   the   edges  of  the
        application sites to denote those buffer areas.
     o  The  structural  integrity   of the  Kunze  Creek  bridge
        should be determined.
     o  If  the ground should  freeze  for an  extended  period  of
        time,  sludge  application should  cease  as  a  precaution
        against sludge runoff in the event of a heavy rainstorm.
Groundwater

     Description of  Existing Environment.   Metro and  CH2M Hill
have  conducted  extensive  groundwater  reconnaissance  of  the
Armstrong  tract  in general,  and  specifically for  the proposed
sludge  application  areas   (Metro  1982a).   Fifteen  groundwater
monitoring  wells were  drilled during  June  to  September  1982
(Figure  3-5) .   Hydraulic conductivity  tests  were  conducted  at
nine of the wells.

     The proposed demonstration sites overlie an aquifer that is
isolated by  Rock Creek,  Kunze Creek, and the North  Fork  of the
Stillaguamish River.   The  aquifer  is  underlain by a  layer  of
Vashon  till, which  has  low permeability  and  results in  the
occurrence of perched aquifers.

     The aquifer is  recharged from groundwater  moving laterally
downslope  from the  north,  and from direct precipitation  on the
site.   Groundwater  tends  to move  east,  south,  and  west,  and
discharge  through  springs  and  seeps  along  the  cliffs  and
eventually  into  Rock  Creek,  Kunze Creek  and  the North  Fork
Stillaguamish River.  The hydraulic  gradient  for sites has been
approximated at 0.0143, or a drop in water level of 1.4 feet for
every 100 feet of horizontal distance.   An estimated 6,300 cubic
feet of groundwater are discharged from the site each day-
                              125

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                                            SOURCE: METRO 1982a
        FIGURE 3-5
    Well  Location
 Pilchuck  Tree Farm,
Arlington, Washington
                                        • legend-
 Groundwater Monitoring Wells
  G 4-Inch Diameter
  • 2-Inch Diameter
 Domestic Water-Supply Wells
  ® Field Verified
  O Unverified
  Q_Spring
t—j1 Hydrogedogic Profile
   I Not Part of Site
                          126

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     The  depth  to  groundwater  is  highly  variable  but,  in
general,  it  is shallowest  at  the north  and south  ends  of the
sites and deepest in the  middle  of the  site  (Table 3-15)  (see
Appendix  F for  a hydrogeologic  profile of  the  site) .   Metro
studies   estimate  the   seasonal   fluctuation  of  water  table
elevations to be from 1-6 feet.

     Groundwater  quality  data have  been  gathered  to  provide
preproject information  for all parameters  to be a  part  of the
site  monitoring  program  (see Table   3-13) .    Those data  are
presented  in Appendix F.   Samples  were  also taken from domestic
wells  located  north  of  the   site.    Results   of   those  tests
indicate  that  the well  water quality  exceeds the drinking water
standards  for coliforms.

     Assessment of Impacts.  According  to  40 CFR  Part 257  (see
Appendix  G)  "A  facility or practice  shall not  contaminate an
underground  drinking   water   source  beyond  the  solid  waste
boundary..." or  any  alternate  boundary  specified  by the State.
The  aquifer  beneath  the  Pilchuck sludge  application  site is
considered to  be  an  underground drinking source because,  1) it
supplies  drinking water  for   human  consumption,   and  2)  the
groundwater  contains  less  than   10,000 mg/1   total dissolved
solids.   As defined  by  40 CFR Part 257,  "contaminate" means to
introduce  a substance  that would cause  1)  the  substance in the
groundwater to exceed the maximum contaminant level specified by
EPA  in  the Primary  Drinking  Water  Standards  (see  Appendix F,
Table F-6  or Appendix  G Section 257.3-4  Groundwater),  or  2) an
increase   in   the  concentration   of   that  substance  in  the
groundwater where  the  existing concentration of that substance
exceeds the maximum  contaminant levels  specified in the Primary
Drinking Water Standards.

     The  most  likely impact  of the  proposed project  would be
associated with  the  movement  of  nitrate  (NO--N)   from  sludge
into the  underlying  groundwater.   Research at  Pack  Forest has
indicated  that  nitrate  is the  most likely  constituent to  leach
to groundwater;  (Vogt in Bledsoe  1981).  Nitrate is very mobile
and  is  generally  the first pollutant to  appear  in groundwater.
Edmonds  and  Cole  (1982)  have estimated  a  NO--N  loss   of 75
pounds per acre for  the first  year following sludge  application
(see Appendix B for a detailed description  of nitrate leaching).
Assuming  a worst-case  situation,  approximately  5,400 pounds of
NO--N  may be  leached  from the   site  during  the  first  year,
approximately 15 pounds per day.

     Studies have  shown  that  in  soils having  relatively high
hydraulic  conductivity  and   few  intrusions   of   impermeable
materials  (i.e.,   clay   seams   or   large  boulders),  pollutants
entering the groundwater  tend  to move laterally  in a thin layer
on the surface of the aquifer with little mixing below 5-10  feet
of depth  (Keeley pers.  comm.).   The contaminated zone deepens as
the  distance   from  the  source  increases;   however,   the  NO..-N
concentration tends to  become  diluted as a  result of dispersion
and diffusion.
                              127

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    Table 3-15.  Depth to Water, Hydraulic Conductivity and Water
Level Elevations of Test Wells, Pilchuck Tree Farm Demonstration Project
Well Number
or Owner
1
2
3
12
13
14
15
Fryrear
Wilson
Witscher
Westerly Spring
Well
Elevation*
1,000.0
852.2
881.5
979.7
967.9
992.0
997.2
1,003.6
1,009.7
1,019.1
918.3
Depth to
Water
(Feet)
53.3
22.3
-
57.1
46.1
48.0
52.6
23.7
36.3
13.1
0
Water Level
Elevation
946.7
829.9
-
922.7
921.8
944.0
945.3
979.9
973.5
1,006.0
918.3
Hydraulic
Conductivity
(Feet per Day)
11
33
-
-
-
-
-
-
-
-
-
 *Well No.  1 elevation set by at 1,000 feet.  All other elevations were
  established relative to that arbitrary reference elevation.
 SOURCE:   Metro 1982a.
                                    128

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     Assuming  a worst-case  condition,  based  on  University of
Washington  data,   CH2M  Hill  calculated   that  sludge  could
contribute  5.9  mg/1 NO.,-N  beneath the  site during  the months
of  September   through  December.    During  the  the  year  of
application and  for  approximatley  1  year  thereafter.  During the
remainder of each  year nitrate values are  expected  to be lower
because  of  seasonal  percipitation  and  resulting  groundwater
recharge.   Background  nitrate levels directly  beneath the site
have  not been  measured,  however,  Metro collected  groundwater
quality data during 1982 from Well No.  1, just north of the site
and  from • two  adjacent springs  (Figure  3-5) .    Average  nitrate
concentration from those sites  is  2.4 mg/1,  a  value  of which is
probably  representative of  groundwater nitrate concentrations
beneath the site.

     With   this  assumed   background   concentration  and  the
estimated   5.9   mg/1   increase   from  the   project,   worst-case
groundwater  nitrate  levels  are  estimated  to  reach 8.3  mg/1
nitrate.   This  value  is   less than  the   EPA  drinking  water
standard of 10  mg/1  nitrate.   Groundwater  inflow from the north
was not  included in  CH2M Hill analysis  and  would result  in some
dilution  of   the   computed  nitrate   concentration.    Nitrate
concentration  are   expected  to  decrease  significantly  in  the
years following  application.

     Even  though NO.,-N concentrations  would increase with  the
project, no drinking water  supplies  would be affected since all
private  wells  are  located  north and up-gradient of  application
areas.   The water  level elevation  of a private  well  closest to
the application site is approximately 27 feet  higher than that
of  the  closest monitoring  well  on the application  site  (Table
3-15) .

     Other pollutants such as heavy metals would not be expected
to  increase in  concentration in  the  groundwater after sludge
application.   Fecal  coliforms  have  been  found  to  move  from
sludge  into soil,  but  beyond 5  cm  (approximately   2  inches)
coliforms rarely survive (Edmonds and  Mayer in Bledsoe 1981)  .
However, because of  the isolated nature  of  the aquifer,  and the
groundwater  flow away  from water supply  wells,  any increased
concentrations   of   other   pollutants   would   not  affect  any
beneficial uses of the groundwater resource.

     According  to  Metro  (1983d),  the  larger  of the  storage
alternatives, the 1 mg sludge basin,  would be constructed with a
20-mil PVC  liner to prevent  leaching into  the  groundwater,  and
a  leachate  monitoring  system of  4-inch   perforated  pipe  to
collect  any material   that  might  accidentally  leak from  the
lagoon.  Rainwater  that might  collect in  the  basin following
removal  and application  of  sludge  would 'be   spray-applied  to
approximately  5 acres  of land near the  sludge  basin.   During
sludge trucking  and  application,  the outside of vehicles would
be washed on a concrete apron at the sludge handling site.  Wash
water would be  collected and mixed with  sludge  in  the sludge
storage  basin.   No adverse  impacts  are  likely to result from
that activity.


                              129

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     Groundwater in the vicinity of the proposed location of the
sludge  basin   trends   southwest  toward  Harvey   Creek.    The
estimated discharge of groundwater in that area is 46,000-69,000
cubic feet per day (Metro 1982a).

     The rainwater collected  in the empty sludge  storage  basin
would  be  approximately  200,000  gallons  per  year.   The  water
would be  spray applied during  the summer months  when  nutrient
and moisture demand are greatest.   An  estimate of 100 pounds of
NO..-N  would  be  applied  per   acre,  well  below  the  nitrogen
requirements of an unfertilized Douglas-fir  forest.   On 5 acres
of land, 200,000 gallons of water would be slightly less than 1
gallon  per  square  foot  of  area.   It  is  anticipated  that
virtually all  of  the water  and nitrogen would  be taken  up by
trees and understory vegetation.

     Metro has defined a program to monitor  groundwater quality
based on  sampling  frequencies,  parameters shown  in  Table  3-13,
and  the location  indicated  in  Figure 3-4  that  conforms  with
DOE's  BMP  (1982a)  recommendations  for groundwater  sampling up
and  down-gradient from  sludge-treated  areas and testing  for
nitrogen, phosphorous, coliform bacteria, and other potentially
harmful constituents.

     Metro's  proposed monitoring  response   plan  would  include
action in the event groundwater from monitored domestic wells or
site   monitoring   wells   reached  one-half   of  the   maximum
contaminant values in  drinking  water as allowed by  EPA (40 CFR
Part 257) .  This would allow Metro to initiate corrective action
well before maximum allowable contaminant levels were reached.

     Mitigation Measures.

     o  Metro  should  determine   the  best   location  for  the
        rainwater   spray    application   site   to  avoid   any
        possible downstream contamination.
     o  Metro  should  establish   a monitoring   well  to  test
        groundwater   immediately   downslope   of   the   spray
        application site.


Wildlife

     Description  of  Existing Environment.   Preliminary surveys
of the wildlife resources of the Armstrong tract and 70 acres of
the  proposed  sludge  application  area  were made in  1982  by Dr.
Steven  West of  the  University  of  Washington  and  by  Jones &
Stokes  Associates  staff.   The  70-acre site  is characterized by
blocks  of  even-aged  7-,  12-, and  24-year-old Douglas-fir, with
some  scattered western hemlock and grand  fir.   Salal,  Oregon
grape,  blackberry,  Indian plum and sword  fern  constitute the
more common understory species  in the plantation areas.
                                130

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     The  proposed application  areas  are  bordered  by riparian
vegetation  (red  alder,   vine  maple,  salmonberry,  blackberry,
horsetail) along Kunze and Rock Creeks and the North Fork of the
Stillaguamish River, and older growth Douglas-fir forests.

     Wildlife  resources   include   a  variety  of  herbivorous,
insectivorous,  carnivorous and  granivorous  mammalian species.
Mammals  known  to occur on the site  include  Townsend chipmunk,
snowshoe  hare,  montane shrew,  mountain beaver,  striped  skunk,
blacktailed deer, raccoon, opossum,  field voles, and forest deer
mice.

     No  detailed  site  surveys  of wildlife  have been completed;
however,  the  University   of   Washington  will  be  initiating
intensive baseline  surveys as  a part  of  the  sludge application
program  to  begin later in 1983  (Metro 1983d).   Inventory work
would  include  an intensive  survey  of  seasonal and  a relative
abundance of vertebrates (birds, amphibians, reptiles, mammals).
Specific investigations would include:

     o  Material balance study. •
     o  Fecal studies of nutrients and heavy metals.
     o  Measurements  of  nutrients  and heavy  metals  in  soil-,
        ground-, and foliage-dwelling invertebrates.
     o  Measurement of heavy metals  in tissue samples.

     Avian  species  known  or  expected to  occur in  young-aged
Douglas-fir forest  include the red-tailed hawk, goshawk,  common
crow,  black-capped  chickadee,  golden-crowned  kinglet,  winter
wren,  song  sparrow, and  band-tailed pigeon.   A  more  extensive
list of resident and seasonal bird species would be developed as
a part of future University of Washington field surveys.

     Although  no site-specific  field  survey  of reptiles  and
amphibians  has  been  completed  at  the  Pilchuck site,  second
growth  Douglas-fir  forest is  known  to  support  a variety  of
reptiles   and   amphibians.    These  include   the   northwest
salamander, long-toed salamander,  western red-backed salamander,
western toad, and Puget Sound red-sided garter snake.

     No  endangered  or threatened  wildlife  or plant  species  or
critical  habitats  are  known  to   occur  on  the  site,  although
concentrations  of bald eagles are  known to  winter  along  the
North Fork Stillaguamish near and downstream of the project area
(Appendix D).

     Assessment  of  Impacts.    The  application  of  sludge  by
spraying into  and over the Douglas-fir plantation  would  affect
wildlife species  in several ways.   Some  small percentage  of the
wildlife  may  come  in direct  contact  with  sludge during  the
actual  application   of sludge.    Some bird  species  would  be
particularly vulnerable  (nesting  birds  and the  more  sedentary
bird species such as the winter wren), whereas others could more
readily  flee  the area.  Any  mortality resulting  from spraying
activities would  be small and would  not adversely  affect  the
long-term viability of the wildlife populations.


                               131

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     Other wildlife  would  be  affected  by  ingestion  of  sludge
during feather preening  or  fur grooming, or  when  searching for
and  consuming  food   that   was   sludge-covered.    Examples  of
ingestion  might   include  black-capped  chickadees  consuming
sludge-covered   catkins;   flickers   and   downy   woodpeckers
inadvertently  ingesting  sludge  when searching  under bark for
insects;  shrew-moles ingesting sludge burrowing  in leaf litter;
black-tailed deer  consuming sludge-covered forage;  and  striped
skunks ingesting sludge  while  rooting in leaf litter and ground
cover.

     West  et  al.   (1981a)  and West  et  al.  in Bledsoe  (1981b)
studied  the  impact of sludge  application on~~~black-tailed deer
and  several  small  mammals  at   Pack  Forest.   Some  of   their
findings were as follows:

     o  Liver  and  kidney  tissue  levels of  heavy  metals  were
        generally  higher in  small  mammals from  sludge-treated
        areas  than   from  control  areas;   however,   no  such
        increases were observed in black-tailed deer.
     o  High concentrations  of cadmium  were  found  in only one
        species of small mammal.
     o  Concentrations of cadmium were  found to  be  higher  in
        kidney tissue than liver tissue.
     o  Lower heavy metal tissue concentrations were found  in
        herbivorous (leaf-eaters) and granivorous (grain-eaters)
        species than in insectivorous (insect-eating) species.
     o  Plant  species  consumed  by  herbivorous  species  absorb
        metals in  varying quantities (Table  3-16),  but  cadmium
        concentrations in kidneys of herbivores were below  those
        known  to   be  acutely  toxic  in   humans  and  laboratory
        animals.

     A third possible  means of sludge affecting  wildlife  would
be from bioaccumulation:   animals consuming lower forms (plants,
insects, or other animals) that have accumulated heavy metals.

     Evidence  to  date indicates  that  bioaccumulation of   heavy
metals does occur  when sludge is applied to  land,  particularly
in   insectivores.     West   et    al.   (1981a)   found   cadmium
concentrations in  the kidney  cortex of  shrew-moles  taken from
sludge-amended sites  at  the Pack Forest to  be near  the  levels
known to be physiologically harmful.   According to Clark (1979)  ,
lead and cadmium accumulate in bats and shrews, possibly because
of their high metabolic rate and diet of insects.

     Wade, et al.  (1982), Helmke  et  al.  (1979) and  Beyer  et al.
(1982)  established that  earthworms  from sludge-amended   sites
contained  significantly  more cadmium than  did earthworms  from
control  samples.   Concentrations   of   cadmium   in  earthworms
studied  by  both  Helmke  et  al.   (1979)  and  Beyer et  al.  (1982)
were  found  to be  as  high  as 100  ppm.   No  studies  have  been
completed analyzing the effects of earthworm ingestion on higher
trophic organisms.  Wildlife  species that do  consume earthworms
as a  normal  part of  their  diets (e.g.,   skunks,  shrews,  moles,
passerine  birds)  could  be  exposed  to  large   concentrations  of
cadmium.

                              132

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                            Table 3-16.  Metal Concentrations (x±S.D.) in Plant Species Found on
                                Sludge-Treated and Control Areas at Pack Experimental Forest
Co
CO
Zinc
Control Sludge
Copper
Control Sludge
Lead
Control Sludge
Cadmium
Control Sludge
Metal content
Salal

Fern

Oregon grape

Blackberry

Ocean spray

Rose

Thistle

22.3
±5.3
19.8
±4.0
26.7
±6.1
33.6
i6. 8
16.1
±3.7
6.9
i5-6
29.2
±10.3
37.0
±7.8
31.8
±9.0
29.5
±7.3
56.4
±15.9
33.2
±9.8
22.6
±8.4
327.5
114.3
5.25
±1.4
4.86
to. a
9.6
±3.9
5.94
±1.2
8.8?
±1.0
5.6
±0.8
10.7
±0.5
- lig/3
4.87
±1.6
6.68
±2.1
9.2
±4.8
5.9
±1.2
7.14
±0.9
4.6
±0.6
14.3
±2.4
O.f>
±0.3
1.5
±0.6
2.2
±0.4
1.5
±0.6
4.8
±1.8
2.1
±0.&
3.12
±0.0
1.7
±0.6
0.9
±0.3
1.3
±0.6
1.2
±1.0
2.6
±0.6
1.9
±0.3
1.7
±0.5
0.09
±0.03
Q. 09
±0.05
0.02
±0.02
0.04
±0.03
0.26
±0.08
0.03
±0.02
0.19
±0;02
0.43
±0.38
0.15
±0.09
0.06
iO.02
0.25
±0.12
1.22
±0.42
0.10
±0.03
2.92
±0.67
                         SOURCE:  West et al. 1981a.

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     Very  little  is  known  about  potential  chronic  toxicity
impacts on wildlife  or bioaccumulation in the vast  majority of
wildlife species.  More study is required on this subject before
conclusions can be reached.   Wildlife  could  also be  affected by
changes  in flora  caused by  sludge application.   West  et  al.
(1981a) found  that  the growth of some  understory plant species
was increased by sludge application, and that any shift in plant
community  structure  would  alter  the  species  abundance  and
composition  of  small  animals.   Reduced  species  numbers  and
abundance  on  sludge-amended areas  were found, and deer use and
population density  of  sludge-amended  areas  increased  (West et
al. in Bledsoe 1981b).

     Some  populations  of  wildlife  species  may  increase  in
sludge-applied areas  in response to the more vigorous growth of
understory  vegetation.   Such population  increases  have  been
previously observed at the University of Washington Pack Forest.

     In  all   likelihood,  some  or  all of   the  above-mentioned
impacts would occur at the Pilchuck site.   Continued research in
this area by the University of Washington should provide greater
understanding of many of the currently uncertain impacts.

        The  U.  S.  Fish  and  Wildlife  Service  (USFWS)   (see
Appendix D)  has identified  three  major concerns  regarding  the
on  the bald  eagle  which  should  be  considered in  evaluating
potential  impacts of the proposed project:

     o  Loss of streamside habitat perch sites.
     o  Disruption   of  habitat  and   eagle  activity  during
        construction and operation of project facilities.
     o  Contamination  of eagle  prey  items  downstream of  the
        project area.

     Because  the  proposed   project would   not  result  in  any
construction activities near either the North Fork Stillaguamish
River or Kunze or Rock Creeks, no streamside habitat loss (i.e.,
perch sites)  would occur.   Furthermore,  it  is  judged that since
any project  construction  (sludge storage basins) would be  well
away  from  the  Stillaguamish  River  (approximately  1 mile)  and
project  operation  would  be  intermittent  and  of. a  short-term
nature  (7-8  months),  neither bald eagle habitat  nor  bald eagle
feeding or perching activities would be adversely affected.

     Contamination of  any eagle  prey species downstream of the
project  area  is  a  highly  unlikely   event.  Please   refer  to
descriptions of the  likely  impacts  on  surface  water  and aquatic
ecosystems as presented in other sections of this EIS.

     Mitigation  Measures.    Metro  has proposed  that  sludge
application on  the 70-acre site  be terminated  in mid-March to
minimize the impact of sludge application on nesting birds.
                              134

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Silviculture

     Description  of   Existing  Environment.   The   two  sites
scheduled to receive  the  first applications of sludge represent
different age phases of a Douglas-fir forest.  The southern site
contains a stand of 24-year old Douglas-fir.  Western hemlock of
approximately the same age are scattered  throughout the stand.
The diameter at breast height  (dbh) ranges from 5-18 inches, and
total tree height varies  from 40-80  feet.   Current  stocking is
about 300 stems per acre,  with trees spaced 10-20 feet apart.  A
commercial thinning  (removal  of merchantable  trees)  is planned
between 1983 and 1987. The stand is planned for clearcut harvest
in 2000.

     The  northern  site  contains   two  Douglas-fir stands.   The
older  of  the   two  stands  was  planted  in  1971  and  contains
approximately 21 acres near the northern  boundary of the site.
Grand   fir   of  approximately  the   same  age   are  scattered
throughout.  The stand ranges  in  height from 20-25  feet and has
an average dbh  of 4 inches.   Tree  spacing varies  between 10 and
12  feet,  yielding  a  stocking rate  of  350-400 stems  per acre.
Basal area (sum of cross sectional areas at breast height of all
trees)  is  about  35   square   feet  per acre.   Two  commercial
thinnings are planned; the first  between  1985 and 1990  and the
second  between  2000   and  2020.   Clearcut  harvest  is  planned
between 2015 and 2020  (Staringer pers. comm.).

     The  younger stand  on the  northern  site  covers about  37
acres and was planted  in  1976-1977.   Tree height  ranges between
6  and  12  feet  with  a  dbh  between  1.5-2.0 inches.   Current
spacing is about 6 feet, with  a stocking of about 600 stems per
acre.

     A precommercial thinning  (removal of nonmerchantable trees)
of both sites is scheduled for the years between  1983 and 1986.
Commercial thinnings  will  take place between  1995 and  2000 and
between 2005  and 2010.  Final  harvest  will  occur between  2020
and  2025.    A   complete  stand  history  for  both  sites  is  in
Appendix C.

     Productivity on both sites is limited by nitrpgen deficient
soils,  low moisture  holding   capacity  of  the  soil,  and Swiss
Needle Cast.  The gravely texture of the soils facilitates rapid
water movement through the soil profile which in turn results in
low  moisture holding capacity  and  loss  of nitrogen.   Swiss
needle  cast  (Phaeocryptopus  gaumanni)   is  a  widespread  fungus
that attacks mainly young  trees.   The  black  fruiting  bodies of
the fungus block the needles'  pores, causing a gradual yellowing
and death of the needles.  Nearly  all trees under the age of 20
years on the demonstration sites  show some sign  of the disease.
The  older  stand on   site  8   was  sprayed with  the  fungicide
Bravo 500 in June 1982 to control  the fungus.
                              135

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     The   two   potential   sludge   application   sites   possess
understory  vegetation typical  of  managed Douglas-fir  stands.
The closed  canopy of  the south  site prevents  direct  sunlight
from reaching  the  forest floor,  resulting in  a  sparse  cover of
understory  vegetation.    Major   species   include   elderberry,
blackberry, sword fern, salmon berry, and some salal.

     The  southern  half  of the  north site  possesses  the  most
dense  and  diverse   understory   community  of   the  potential
application areas.  The open  canopy  of  this  young stand permits
the growth  of  salmonberry, blackberry,  thimbleberry,  and sword
and bracken fern.  The northern half of the site contains a less
dense understory consisting of these same species.

     Because  understory   species retard  the  growth  of  newly
planted Douglas-fir seedlings, herbicides are commonly applied to
Tree Farm stands within 5 years of planting.

     Assessment of Impacts.

     Timber and  Understory Growth —  Application of sludge  to
forestlands  would  provide  the  potential  for  increasing  the
growth  rates  of managed  stands.  Potential  increases   in  tree
growth  following sludge   application  are  due  primarily  to  the
large influx of  nitrogen,  which  often limits  growth on glacial
soils.  Increases in  the  water and  nutrient  holding capacities,
the organic matter content,  and overall  nutrient  levels  also
promote increased tree growth.

     The first noticeable change  in Douglas-fir stands receiving
sludge, is  a  change  in foliage color; from light green to dark
greenish-blue.   This  change  usually occurs  within  1  year  of
application  (Archie  and  Smith in Bledsoe  1981;  Zasoski  et  al.
1977).   Color   changes   usually  occur   in   conjunction  with
increased  growth.   Although  impressive growth  increases  have
often  been noted,  prediction of  a  stand's  response  based  on
previous  studies should  be  done  with caution.   Variability  in
sludge nutrient content,  tree species and age,  site quality,  and
sludge application rate influence tree response greatly.

     The most comprehensive local research regarding the effects
of  sludge  application on tree growth has  been conducted by  the
University  of  Washington  at the  Pack  Forest  site  in  western
Washington  near  Mt.  Rainier.   Although conditions  do not match
those of  the  Pilchuck Tree  Farm exactly,  many  site parameters
are similar.

     Growth  responses  on   the  Pilchuck  north  site   may   be
approximated by the results from a 10-year old Douglas-fir stand
on  a  glaciated site  III  plot at Pack  Forest.  One  year after
receiving  1  inch  of  Metro  sludge,  this  site  recorded a  10
percent height increase and a  58 percent increase  in basal area
over controls  (Henry  and  Cole 1983).   This response seems to be
typical of young Douglas-fir stands.
                              136

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     Growth data  have not been  collected for  plots  similar in
age and site quality  to  the  Pilchuck  south site (age 24).  Pack
Forest research on  older stand  (50+ years)  has shown that those
stands  also  respond  to  sludge  application,  especially  if  the
site is of poorer quality  (Edmonds and Cole 1982); these authors
suggested that  the  optimum stand age  for  sludge application is
between 5  and 30 years.  All trees  on the  Pilchuck  sites  are
within that age  range.   Although the  longevity  of increases in
growth rate is  not  known, Henry and  Cole  (1983)  have found the
response to last at least 4 years.

     The only negative growth responses in Douglas-fir recorded
locally have  occurred following very  heavy  sludge applications
or application to extremely  dense,  young stands (Henry and Cole
1983;  Zasoski et  al.  1977).   The  relatively  small applications
proposed  for  Pilchuck,   coupled  with  the tree  farm's  active
thinning policy,  should  prevent  any negative  growth responses
following sludge application.

     No quantitative data are available concerning the growth of
understory  species   following  sludge  application.   Large  but
variable rates  of  sludge  application have resulted  in  reduced
growth  of  salal  and Oregon  grape  (Edmonds  and Cole  1976) .
Smaller  sludge   applications   have  produced  positive   growth
responses in some species  (West et al. 1981a).

     Application of sludge to the Pilchuck sites would not cause
a  change  in  the management of  the  sites.     Following  stand
harvest and  subsequent  planting,  those sites would  be  treated.
with   a  herbicide   regardless  of   sludge   application  plans
(Staringer pers. comm.).

     Metal  Uptake  — Research  has  been conducted  concerning
possible  increases  in  heavy metal uptake  by  trees  following
sludge application.   Increases in the foliar heavy metal content
of Douglas-fir  seedlings grown  for 1 year in a sludge/soil  mix
were noted only for zinc (Bledsoe  and Zasoski in Bledsoe 1981).
Limited data from sludge application to older Douglas-fir stands
revealed slight increases in foliar concentrations of copper and
zinc   (Zasoski  et  al.   1977).   Cadmium,  chromium  and  nickel
concentrations in that study remained below one ppm.

     Wood  Quality  —   Potential   sludge-induced  tree   growth
increases may result in  a change in the anatomical properties of
the  wood.   Research  on  this  subject is  still  in  the  early
stages.  Preliminary indications are that trees may experience a
slight drop in  specific  gravity (related to  wood  strength)  but
experience no change  in  fibril  angle  (an indicator  of  overall
wood quality)  (Leney and Briggs pers. comm.).
                              137

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     Wood property  changes associated with  growth acceleration
resulting from  the  application of  conventional  fertilizers are
well  documented.   Erickson  and  Lambert   (1958)  measured  an
8 percent decline in the specific gravity of wood from a 30-year
old Douglas-fir  stand  that had experienced  22  percent increase
in  diameter   growth   following  applications   of   a  nitrogen
fertilizer.

     Mitigation Measures.  None required.


Aquatic Ecosystems

     Description of  Existing  Environment.   Three  streams,  Rock
Creek, Kunze Creek and the North Fork Stillaguamish River border
the  proposed  application  sites on  the   east,  west  and  south,
respectively.   Rock Creek  and Kunze Creek were  surveyed during
February and June 1982.  Rock Creek  is characterized by a steep
gradient comprised of mostly  rubble  and  boulders with few large
pools and overhanging banks.  Results of fish surveys indicated
three  age  classes of  cutthroat trout,  and  juvenile  and  smolt
coho  salmon.   Large  numbers  of juvenile  salmon  were seen along
the  entire  length  during  the  June  survey  (Metro  1983d).   A
previous spawning survey conducted  by the Washington Department
of  Fisheries   indicated  coho  spawning  between  the mouth  and
river mile 1.5.

     Kunze Creek  is  characterized by a  low to  moderate  stream
gradient in the upper portions  of the creek,  and a steep,  rocky
gradient at  the lower reach.   Fish electroshocking  surveys  in
February yielded low numbers of coho  salmon  and cutthroat trout
but like Rock  Creek, greatef  numbers  were found during the June
survey.

     Although no steelhead trout were found  during the surveys,
as  a  general  rule,  steelhead  utilize  small  feeder  streams
similar to Rock and Kunze Creeks.

     The North  Fork Stillaguamish  River, immediately  south  of
the site, is  recognized  as  an  important  waterway for anadromous
fish.  Eight  anadromous  species are known to utilize the  North
Fork and its tributaries.

     Assessment of Impacts.   As discussed in the  surface  water
evaluation of  the Pilchuck  project,  surface  water contamination
from  sludge runoff  is  not likely to be  a significant problem.
Therefore,  aquatic  resources  are not likely to be  affected  by
sludge runoff.

     In  the  event sludge  were to  enter either Kunze or  Rock
Creeks the impact  on  fish would depend  on such  factors  as the
time  of  the  year,  water  temperature  and dissolved  oxygen  (DO)
content, stream flow, BOD and quantity of the sludge,  dilution
and  dispersion  of  the   sludge in  the  creek.    Upper  Kunze
                               138

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Creek would  probably represent  the portion  of the  two creeks
most  vulnerable   to  the  impact  of   a   small  sludge  spill
(accidental spraying of sludge into the creek).

     In the  unlikely event of a  large spill on Kunze Creek, a
majority  of  the  fish  and  invertebrate  populations  in  the
affected  portion  of the  creek  would  probably be  killed  off
because of  the high BOD and  subsequent lowering  of dissolved
oxygen and physical  smothering.

     If a small sludge  spill  should occur,  the resultant impact
would depend  on the  factors  mentioned earlier  in  this impacts
discussion.   The  worst-case   situation likely would be  when
stream  flows  are  lowest  and  water  temperatures  are  highest
(September or  early  October),  or when  eggs  had been deposited.
Fish embryonic  and  larval  stages  are  especially  vulnerable to
reduced DO concentrations (EPA 1976b).

     Mitigation  Measures.   The  mitigation  measures  previously
described for  surface water impacts should  assist  in minimizing
the likelihood of  accidental  spills.   In addition,  stream water
quality tested bimonthly  should  be  analyzed  in  terms of  EPA
(1976b)  criteria for protection of freshwater organisms.


Land Use

     Description of  Existing  Environment.   Land surrounding the
Pilchuck  Tree  Farm  is  a  mixture  of  residential,  forestry,
recreation  and agricultural  uses.   The  predominant  zoning is.
rural  conservation,  forestry,  agriculture  and  forestry  and
recreation (Figure 3-6)  .

     The  south demonstration  site,  covering  approximately  15
acres of  24-year old Douglas-fir,  is  completely  surrounded by
closed-forest landscape.  The North  Fork Stillaguamish River is
located approximately  200 feet east  of the  demonstration  site
and  Cottonwood  Terrace recreation  area  and  Kunze   Creek  are
located  approximately  3,500   feet   south  and  200  feet  west,
respectively, from the demonstration site.   The site lies within
the forestry and forestry-recreation zoning districts.

     The  north  demonstration  site,  approximately  55  acres,  is
bounded by  forest and  Rock Creek  on the  east,  forest on  the
south,   forest  and  Kunze  Creek  on  the west  and  forest  and
residential development on the  north.   The  11-lot residential
development approximately  500 feet  north  of  the  demonstration
site  was  established   in   1979   and  currently   has   eight
single-family and mobile home  dwelling units.  The  north site is
covered by Douglas-fir  and grand  fir  trees,  and lies within the
forestry zoning districts.
                                139

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ft--- ft   ft--- ft-- • ft ••' Qi
pgy  g&   (jj? • - gw •  i^w. • • GUf
****'  '******  ^TUJU  ^£L  A*.***.' ff^
                            SOURCE: SNOHOMISH COUNTY. 1982
      FIGURE 3-6
   Zoning  in the
 Project  Vicinity
                              r—legend=
RC MURAL CONSERVATION


   AGRICULTURE 10 ACRE
   FORESTRY AND RECREATION


   FORESTRY
                         140

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     All  three   alternative   sludge   handling  facilities  and
equipment  storage  areas   are  completely  bounded  by  forest
vegetation.   The  zoning  in these  areas  is either  forestry or
forestry-recreation,  depending   upon   exact  location  of  the
facilities.

     Land Use Plans and  Policies  --  A number  of subregional,
county and municipal  plans and policies affect  future land use
in  the  Pilchuck  Tree  Farm  area.  The   Snohomish  Subregional
Development Plan  is a comprehensive growth management strategy
for  the  development  of  the  Snohomish subregion.    This  plan
contains  broad  goals  and  policies covering three  major issues
currently  facing  the  subregion;  activity   centers,  housing and
public services (PSCOG 1979).

     The  Snohomish  County  Shoreline  Management  Master Program
(September  1974)    is   comprehensive  plan  for  the  effective
management of shoreline resources.  The plan contains goals and
policies,  use  regulations,  and  maps which  regulate  various
activities and development  within the  shoreline.  The shoreline
is  generally  defined  as  the  area  within  200  feet of the high
water  level'  including the  entire floodplain  and  associated
wetland of a  waterbody.

     The  County's  Arlington  Area  Plan (AAP)   (March  1975),  a
guide  to  the  future development  of the Arlington  area,  is the
most important land use plan for purposes of project assessment.
The plan's  objective  is  to perpetuate and  reinforce  the rural
county environment.  The  City of Arlington  is presently  in the.
process of updating its comprehensive plan.

     The  AAP's  goals  and  policies are  included in  the  plan's
land  use  map.   The  map  depicts  the  recommended  land  use
designations  for   the  Arlington  planning  area  through  1990
(Figure 3-7).

     Assessment of  Impacts.

     Consistency With Land  Use Plans and Policies -- The use of
the  demonstration  sites  for   sludge  application   would  be
consistent  with   one  of  the  major purposes  of -the AAP:   to
reinforce management practices which would protect forestry and
timber long-term  productivity.  To accomplish this,  the plan's
policies deal with  using  forest  management methods that sustain
high yields,  provide  multiple uses of the forest, and  are in
accordance  with  sound   economic,  ecological,   and  land  use
planning principles.

     Demonstrations at  Pack Forest near Eatonville,  Washington
have shown that tree growth increases significantly after sludge
application.   In  the long-run, sludge  application to forestland
would help to sustain yields and consequently the forest economy
of the county-
                             141

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                             >^*'"^  ™^™.*g
        SOURCE: ARLINGTON AREA PLAN. SNOHOMISH COUNTY. 1975
    FIGURE 3-7
    Projected
1990 Land Uses
                          =legend=
 R  MURAL (.1-.4 OU/A)

   PARK/OPEN SPACE
   AGNICULTUME (10U/10A)


''  COI-I|IUNITT FACILITIEi/SCMOOLf
                    142

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     The application of sludge to forestland would be consistent
with the  plan's policies of  using innovative methods  of waste
disposal  and  conducting  short-term  uses   of   land  for  waste
disposal  in  such a manner  that public benefits are maximized,
while detrimental effects on the environment are minimized.

     The   12-month  Pilchuck   demonstration   project    is   an
innovative method in sludge disposal.  These demonstration sites
have  been   selected   because  of   their   relatively  isolated
locations and potential for limited environmental problems.  The
sites would  be monitored  for  environmental effects  during and
after the sludge application.

     Direct  and  Indirect Land Use Changes  —  The demonstration
project would  not  change the land uses  on the  tree  farm or in
the  surrounding area  in  the   short  run.    The   application  of
sludge to forests would enhance the forest growth by providing a
source of nutrients.

     Concern  has   been   expressed   by  the  Pilchuck  Citizens
Advisory Committee  that  if  land uses  on  the tree farm or in the
area change, the new land owners and/or residents could possibly
not know of the sludge application.  In response to this concern
the tree farm will amend its county land records to describe the
actual   sites   of   sludge  application,   amounts,   dates   of
application, and concentration of  heavy metals in  the  sludge
applied.  Any  title search  connected with property  within the
tree farm would contain a reference to sludge amendments.

     The  proposed  application  rate  of  20  dry  tons/acre  would
result  in a  cadmium  loading  of 2.0  pounds/acre  (2.2  kg/ha).
Based on  EPA regulations  (40  CFR Part  257)  at  that rate,  the
application  sites  could  be used in  future  years for production
of food chain  crops so long as the soil pH  was  adjusted to 6.5
or  greater  whenever  crops  were  grown.    The  project  would
therefore not preclude any future uses of the site, even for the
most  restrictive   use  -   production  of  food   chain  leafy
vegetables.

     Property values surrounding the  tree  farm  are not  expected
to decrease  as  a result  of  the  sludge application either in the
short or  long-run.   The  Snohomish County Assessor's  Office has
provided a written opinion to the tree farm that property values
are  unlikely  to be  affected  by the demonstration  (Pilchuck
Citizen's Advisory Committee minutes October 1982).

     Mitigation  Measures.   Based  on  initial  results of  spray
application  operations  the buffer  zone  between  the  residences
and the north  demonstration site could be  increased  to provide
additional protection from potential odors, noise, and aesthetic
changes.
                              143

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Population and Housing

     Description of Existing Environment.

     Existing Population and Recent Trends — According to U. S.
Census  data,  the  1980  population  of  Snohomish  County  was
337,720.  The population growth rate in Snohomish County between
1970   and   1980   was   approximately   27.3   percent.    The
unincorporated areas  grew at  a  considerably higher  rate  (45.9
percent) than did the incorporated areas (10 percent).

     For the purposes of this impact analysis, population growth
in  sections  13,  24,  25  and  36  (T32N,  R5E)  and sections 17
through 20  and  29 through  32  (T32N,  R6E)  was  evaluated.  This
study area  is within census tracts  534 and  535.02  (See Figure
3-8) .   Table 3-17  indicates  the  population  changes  in census
tracts  534  and  535.02  from  1970  to  1980.   The  population
increase in tracts 534 and 535.02 can be partially attributed to
people wanting to live  in a rural  setting  and moving  out of the
local communities.   Census  tract 535.01, which  is  not directly
in  the  study area,  predominately covers the  City  of  Arlington.
Since  1970,  tract  535.01   has   grown  by  approximately  30.2
percent.  The City of Arlington  has  grown  rapidly  over the last
10  years,  from a  population  of  2,261-3,282.   The 1979 median
family  income  level  of residents  was  $21,193 in tract  534 and
$17,791 in tract 535.02 (Cost pers. comm.).

     Projected Populations  --  Snohomish County  is  projected to
increase in  population  from 337,720  in 1980  to  430,452  in 1990
and to  533,388 in 2000.   The project  study area is projected to
grow from 6,731 in  1980 to  8,951 in 1990 and to 10,467  in 2000
(Cost pers. comm.).

     The 1975  Arlington Area  Plan  projects that  the  Arlington
planning area, which includes  the  project  study area,  will grow
at  a slightly  higher  rate between  1980  and  1990  than  will
Snohomish County  as a  whole.   The  Arlington planning  area is
expected to grow by  38  percent,  and  the  county  by  34.3 percent.
Most of  the growth  in  the  Arlington planning  area will likely
occur in the  vicinity  of  the Arlington airport  (Arlington Area
Plan 1975;  Newman pers.  comm.).

     Existing Housing Conditions and Recent Trends  —  According
to the 1980 census,  Snohomish County had 131,206 dwelling units.
Of this total, 40,410 new dwelling units were built between 1970
and  1980.   Census tracts  534  and  535 had  1,755  new  dwelling
units  from  1970-1980.  This  number  represents dwelling  units
constructed within the  1970 census tract  boundaries.  The City
of  Arlington's  housing stock  increased by  474 dwelling  units
from 1970-1980.

     Housing in the  study area is generally  sparsely  scattered
and  on  lots of  2.3  acres  or  larger.   In  1979, a large tract
survey  (section 24,  T32N,  R5E)  was created just northwest of the
                              144

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       ^CENSUS T
                  CENSUS
                      535.O2
         FIGURE 3-8
Census Tracts in the Vicinity
 of the Pilchuck Tree  Farm
             145

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                    Table 3-17.  Population Changes from 1970 to 1980 in Census Tracts  in the Vicinity
                                                of the Pilchuck Tree Farm.
Population
Census Tract
534
535.02
TOTAL
1970
1,439
2,247
3,686
1980
2,288
4,443
6,731
Numerical Change
1970-1980
849
2,196
3,045
Recent Change
1970-1980
59
97.7
82.6
(TV

             SOURCE:  Cost pers. comm.

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1983 proposed  sludge application  site.   The  survey  created 11
lots  varying  in  size  from  approximately  5-6  acres.    At  the
present  time,  there  are  eight dwelling  units  located  in this
large tract survey.

     From 1979 to  1981, there were no new recorded plats in the
study area.  During  this  same time period, only five new short
plats  were   recorded  by  the  county.   These  five short plats
created 12 new lots.

     In 1979, 13 new dwelling units, including single-family and
mobile homes, were constructed  in  the project area.  Twelve new
dwelling units were  built in the  project area in 1980.   And in
1981,  14  new dwelling  units were  constructed,  the approximate
locations of  these new dwelling  units are shown  in  Figure 3-9
(Cost and Newman pers. comm.).

     Assessment of Impacts.

     Population Changes — The population of Snohomish County or
the project  study  area is not expected to  increase as  a result
of  the  sludge  demonstration  project.   Metro  is  expecting  to
assign  several  of   its   current   employees   to  work   at  the
demonstration site as  needed.   These  employees would  be working
elsewhere  within  Metro's   system  when  not  on  duty  at  the
demonstration site.   The  number of truck  drivers hauling sludge
within Metro's  system  will not  change  with  the demonstration
project  (Cochran pers.  comm.).   The Pilchuck  Tree  Farm  is also
not anticipating to  add any new employees for the demonstration
project  (Rice and Staringer  pers.   comm.).

     Housing  Changes  —  The housing  market  in  both Snohomish
County and the project study area  is not expected to change as a
result of  the  sludge demonstration  project.   Some  of  Metro's
four employees assigned to the  demonstration  project  might move
into the area to be  closer to work.  The  majority of Pilchuck's
employees already live in  the  area around the tree farm and are
not expected to move.

     Mitigation Measures.   None required.


Transportation

     Description of Existing Environment.   The estimated sludge
hauling distance from Metro's West Point  Treatment Plant to the
storage lagoons on the Pilchuck Tree Farm would be 70 miles each
way.  The proposed haul route from the treatment plant  would be
through Discovery Park to Interstate 5 and north on Interstate 5
to the State  Route  530 exit.  Trucks would then travel  east on
530 to Arlington,  and then  north on  State  Route  9.   The 1981
average  daily  traffic  (ADT)  for  State   Route  530  was  5,400
vehicles,  and State  Route  9  ADT was   2,500  vehicles   (Metro
1983d).
                              147

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          SOURCE: SNOHOMISH COUNTY PLANNING DEPARTMENT. 1982
     FIGURE 3-9
  New Residential
Development  in the
  Project  Vicinity
plegend1
   NEW RESIDENTIAL DEVELOPMENT
        198 1
   NEW RESIDENTIAL DEVELOPMENT
        1980

   NEW RESIDENTIAL DEVELOPMENT
        1979
                     148

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     After  traveling  1.4 miles  on  State Route  9,  trucks would
turn right  on  Armstrong Road, a 20-foot  wide  gravel road which
serves  residents  of  the  Lake  Armstrong  area.   Traffic  on
Armstrong  Road is  partially  controlled  by an  advance warning
flashing  light system  for  eastbound  traffic.   Because  of the
narrow roadway, eastbound  traffic  must pull to  the side of the
roadway to allow westbound traffic to pass.

     Trucks  leaving the  Pilchuck  site  would  not  return State
Route 9 via Armstrong Road, but would instead return via Brakken
Road and Grandview  Road.  Both  roads  are paved,  with stop signs
located at  the intersection  of  Brakken and Grandview  Road and
the  intersection  of Grandview  Road  and State Route  9.  Trucks
entering onto  the State  Route 9 would travel south to Arlington
and return to  Interstate 5 via State Route 530.

     Land  use  along State  Route 530  is  primarily agricultural
with scattered areas of commercial uses  (at the Interstate 5/530
interchange  and  within  the Arlington  City limits).   Land use
along  State   Route   9   and  Armstrong  Road  is  predominately
agricultural and forestry.

     Assessment  of  Impacts.   Sludge  handling  to  the  Pikchuck
Tree Farm during  the  summer months  would call  for 365-520 total
truck loads, with  4-9  trucks  per day  traveling  on the proposed
haul route.   Because  daily sludge production  at  the West Point
Treatment Plant is  greater  during  the  winter months,  more truck
trips could be scheduled  per day  (14-19 trucks per  day)  with
hauling to occur for a shorter period of time  (15-20 days).

     To avoid  potential conflicts with school busing activities,
the Pilchuck  Citizen's  Advisory Committee  has  recommended that
no  hauling be carried  out Mondays  through Fridays  during the
hours of 7-9 in the morning and 3-5:30 in the evening (September
through June).  During the remaining 19.5 hours of hauling time,
the number of  trucks could vary from 1 truck per hour to 1 truck
per  2  hours depending  on the  amount  of sludge  generated each
day.

     The  projected  number  of daily truck  trips would  have  no
measurable  impact  on either  State  Route 530  or State  Route  9
capacities,  contributing only  an  additional 18-38  daily trips
for each roadway.

     Any  traffic   congestion  problems  in   Arlington  or  on
Armstrong  Road that might  be caused  by sludge  hauling trucks
would be reduced by the limitations set on sludge hauling during
the  school  busing  hours.   The  school   busing   hours  also
correspond to  the peak  work commuting hours and  the peak hours
of traffic congestion.   During  the  remaining daylight hours and
at night,  the  traffic volume on Armstrong Road is expected to be
lower than during the peak  hours.  When  sludge hauling would be
most frequent, some traffic delays  on  Armstrong Road may occur,
however, because of the narrow width of the roadway.
                               149

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     Because  both  State  Route  530  and  State  Route  9  are
asphalt/concrete  roadways  in  good  condition,  and  designed  to
handle heavy  truck  loads,  sludge hauling would  not be expected
to cause  inordinate  roadway deterioration.   The Armstrong Road
would be more susceptible  to  deterioration  since it is a gravel
surface road.   Deterioration  would  most likely  occur  at curves
in the road when  gravel  is  pushed to  either side as a result of
traffic movement.   Deterioration would also  occur during  the
winter months, particularly during and after heavy rains.

     Trucks  leaving   Pilchuck  Tree  Farm  would  stop   for  gate
openings and  closure  just prior  to exiting  onto  Brakken Road.
Noise  from   air   and  throttle  brakes,   engine   idling,  and
exceleration  would  occur  at  that  location as  well as  at  the
Brakken-Grandview Road and Grandview-Route 9 intersection.  Some
residents  of  the approximately  20  homes   along   Brakken  and
Grandview  Road   would   be  affected  by   the   truck   traffic,
particularly  during   the  nighttime  hours.   Depending  on  the
frequency interval of truck traffic,  some  minor traffic merging
delays may occur at the intersection of Grandview Road and State
Route 9.

     Mitigation Measures.  The peak hour limitation proposed by
the  PilchuckCitizen's  Advisory  Committee would  significantly
reduce the potential for congestion, delays and accidents, since
trucking would not be carried out when local traffic volumes are
the greatest.

     The  following measures should also be considered  for  the
Armstrong Road area:

     o  Improve the advance warning  signaling device to ensure
        that if functions efficiently and properly.  The warning
        signal  at present  does not  always  operate  when traffic
        is present (Pilchuck Advisory Committee pers. comm.).
     o  Road  signs should  be  erected on Armstrong  Road warning
        motorists of wide-load vehicle use of the road.
     o  Metro   should   coordinate   with  Snohomish  County   to
        establish periodic cooperative  maintenance checks  and
        repairs to Armstrong Road.


Aesthetics

     Description   of    Existing    Environment.     The    south
demonstration site is surrounded by  a closed-forest landscape of
dense  conifers.  A   few  logging   access  roads  are  scattered
throughout the  site  and surrounding  forest.   This  site  is  not
readily visible  from either  the  Stillaguamish  River,  some  200
feet east of the site, or any other  area of Pilchuck Tree Farm.

     The  north  demonstration  site,  located  approximately  500
feet  from  the  tree  farm's  northern  property  boundary,   is
surrounded by conifers  and  deciduous  stands  of various  ages.
                               150

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The  northern  boundary of  the  site is  bounded  by approximately
300  feet  of Douglas-fir  and grand  fir trees planted  in 1971,
with an  average overall height  of 20-25 feet,  and  200 feet of
Douglas-fir  trees  planted  in   1979,  with  an   average overall
height  of  2-3  feet.   Surrounding  the  site  on the  eastern,
western,  and  southern boundaries  are  coniferous  and  deciduous
heights and density.   This site is  currently partially visible
trees of various  ages, from  the  residences  located north of the
Pilchuck Tree Farm boundary -

     There are  four alternative sludge  handling facilities  and
equipment storage areas proposed for the demonstration project.
The  first two  alternatives,  .a 1 mg  basin or a  smaller 'storage
basin, would be located near the BPA transmission line  that runs
north  and south  through  the  tree  farm.   This  cleared  area,
surrounded  by  closed-forest  landscape  is   completely  isolated
within the tree  farm.  A  logging access road is parallel to the
transmission line.

     The  third  alternative would  involve   locating   long-haul
trucks,  storage  tanks,   and   application   vehicles  near  the
application sites.   Equipment  stored near  demonstration  sites
would  be  surrounded  by   forest  vegetation of various  ages,
heights, type and density.  The  equipment would not generally be
visible to anyone except sludge workers and tree farm employees.

     Under  the fourth alternative,  long haul  trucks  would  be
used to store sludge before it is transferred to the application
vehicle.  No site location has been determined yet.

     The  most  perceptible . odor  associated   with  demonstration
sites  is  from  the  forest  itself.    The  perception  of  this
forest-earthy   odor   varies    accordingly    to   individual's
sensitivities as to whether it is pleasant or not.

     The level  of noise associated with the  demonstration sites
varies  depending upon  time of  the  year.    In  the   spring  and
summer  seasons,  motorcycles  and  other loud off-road  vehicles
frequently use  the  logging  access roads.   Certain  noises  from
normal  routine   tree  farm  activities  such   as  insecticide
spraying, thinning,  and harvesting can also be heard during this
time.  Generally, there  is  little noise heard  during  the  fall
and  winter  seasons  except for  a  brief  period during hunting
season.

     Light  and  glare  are  not  currently   emitted  from  the
demonstration sites.

     Assessment  of  Impacts.   During  the  operational  phase,
sludge would  be sprayed onto  the  conifers,   coating  either  the
foliage  or  the  tree  bark  and understory   vegetation with  a
grayish  black  material  that  resembles used  crankcase oil  in
appearance.   As the sludge dries,  it  turns  a lighter-gray color
and forms flakes  on  the needles  and  understory  vegetation.   The
sludge would  remain on the  conifers and understory vegetation
                              151

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until it  is  washed off by  rains.   During the  time  period from
the initial  sludge  spraying to when the  rains  have  removed the
sludge,   the  forest's  visual  quality  would  be  significantly
altered.  After  rains remove the sludge,  the  forest appearance
would return to  normal.   Based on  results at Pack  Forest,  a
majority of the applied sludge was not visually evident 2 months
following application.

     A   few   months  after   sludge   application,   the  forest
appearance  would change  to  a  darker,  richer  green  color and
would  often  appear  healthier  and  more   vibrant.   The  richer
forest color will remain for many years thereafter.

     Long-haul  trucks  carrying  sludge  to  the  demonstration
sites, over  state highways, county and city roads,  and logging
access roads would  not  adversely impact the  aesthetics of these
roadways  unless   an  accident were  to occur  with sludge  being
spilled.

     A distinctive odor would be associated with the operational
phase  of  the demonstration.   The  odor   would  come   from  the
handling  facilities,  equipment storage areas,   and  the spraying
of  sludge onto  the  demonstration  sites.   The  reaction to the
odor  of  sludge  differs  according  to  individual  sensitivities.
Some people  find the odor to be musty, barnyard-like, pleasant
or noxious.  The odor associated with sludge application was one
of the 17 concerns  expressed  by the  Pilchuck Citizen's Advisory
Committee.    The   odor   of   sludge  would   generally   be   most
pronounced when  a large surface area  of  sludge was  exposed to
air, such as during spraying operations.   After application, the
odor  would  abate  and essentially cease  as the  thin  layer of
sludge  becomes  aerobic  (Pilchuck  Citizen's Advisory  Committee
minutes October 1982).

     Noise associated with the operational phase would come from
loading,  unloading,  pumping, and  transferring  sludge  from the
long-haul  trucks to  the  handling  facilities   and  then to the
application  vehicles.  A   certain  level   of noise  would  also
result from the spraying of sludge onto the forest.

     Transportation noise from the long-haul trucks transporting
sludge from West Point to the demonstration sites would increase
significantly along  the haul route and in the vicinity of the
demonstration site.   Hauling of  sludge  would  take  place  on  a
round-the-clock  schedule  with 4-9 trucks  per  day (2-3  times  a
night) entering the demonstration sites (Metro  1983d).

     Light  and  glare  would  be  produced  from  the  long-haul
trucks'   headlights  during  late  night  and early  morning sludge
deliveries.   This  would  create  an  intermittent  nuisance  to
residents along the haul route.

     The  adverse  aesthetics,  odor,   noise,  light  and  glare
effects  from the south site  would  generally not  affect anyone
except  sludge workers  and  tree farm  workers because of  the
                               152

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isolated   location   and   closed-forest   landscape   of   the
demonstration  site.   Summer  residents  of  Cottonwood  Terrace
recreation area, south of the demonstration site, would possibly
be  able  to  detect  sludge  odors  and  noises   depending  upon
prevailing climatic conditions.

     The  adverse  aesthetic,  odor,  and  noise  effects  from the
north  site  may  also  affect  residents  living north  of  the
demonstration site, because of the relatively close proximity of
the site.  Those residents  may be able to  clearly detect sludge
odors  and noises  but are  unlikely to  see sludge  application
vehicles, light and glare, and the sprayed forest.

     Residents  living  along  the  haul  route  would  experience
additional  traffic,  additional  noise,  and  perhaps  some  minor
sludge odors, as the long-haul trucks passed by.

     Mitigation Measures.

     o  Sludge odor drift will be reduced by spraying the sludge
        onto the forest on calm days.
     o  Noise impacts from construction and operation activities
        may be reduced by restricting the use of heavy equipment
        to daytime hours, between 8 a.m.  and 4 p.m.
     o  By increasing  the buffer zone on  the  northern boundary
        of  the  north  demonstration site,  aesthetics and  odor
        impacts on residents to the north may be reduced.


Recreation and Access

     Description  of Existing  Environment.  The Pilchuck  Tree
Farm is used for both passive and active recreational activities
including  motorcycling,   horseback  riding,  berry  and  mushroom
picking,  bird  watching,   hiking,   bow  hunting,   fishing  and
Christmas tree cutting.   The  tree farm has a fairly open policy
on  allowing  people to  use the  land for  recreational  pursuits
(Rice pers. comm.).

     The  Stillaguamish  River,  east of the  demonstration sites,
is used for fishing, swimming and boating.   Kunze Creek and Rock
Creek, which border the north  site,  contain  small  cutthroat and
coho salmon but are not readily accessible for fishing.

     Southeast  of   south  site   is  the   Cottonwood   Terrace
recreation area.  This  6.7-acre site has  approximately  26 lots
with mobile homes  occupied by elderly and retired  people.   The
lots are  leased from the  tree  farm  on  a  20-year basis,  with the
current  lease  expiring in  2002  (Rice pers.  comm.).  The  tree
farm in  1973 dredged  a  small  lake,  locally named Schloman Lake,
for  use  by  the  residents of  Cottonwood  Terrace   (Rice  pers.
comm.).

     Assessment of Impacts.  The demonstration sites, and sludge
handling  facilities and equipment storage areas, would be closed
                               153

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to  recreationists   during  the   operational  phases   of  the
demonstration   and   for   a   12-month   period   following  the
demonstration.  The  closure of  these  areas, and  the potential
loss of recreational opportunities  on  the tree farm from sludge
application, was  one of  17  concerns  developed by  the Pilchuck
Citizen's Advisory Committee.  The  amount of land closed by the
demonstration  would  constitute  less  than  10 percent  of  the
Armstrong  Tract and  less  than  1  percent  of  the entire tree
farm  (Pilchuck Citizen's  Advisory Committee  Minutes  October
1982).    This  small   amount of   land  being closed  would  not
significantly  affect overall  recreation  opportunities  on  the
tree farm.

     Closing  of the sludge  application  area would  reduce  any
potential  adverse  effect to recreationists  in the  short  term.
However, potential long-term effects of  allowing  recreationists
to  use  sludge-amended  land  at  some  future  time  are not well
documented.  Potential  concerns  include  recreational  berry  and
mushroom  picking,  hunting,  and  fishing.  There  has  been very
little  research done  on  the  potential  human health  problems
associated with the  consumption  of berries  and mushrooms  grown
on  sludge  amended  land;   however,  studies  proposed  for  the
Pilchuck  project  should  provide  more  information  on  those
concerns.

     Recreational  opportunities   at   the   Cottonwood  Terrace
recreation area or on  the North Fork Stillaguamish  River  would
not be  adversely  affected by  the  demonstration because of  the
200-foot  buffer  zone  and  the  0.75-mile  distance  from  the
demonstration area to Cottonwood Terrace.

     Mitigation Measures.   The  area  surrounding  demonstration
sites and  the  sludge handling  facilities  and equipment  storage
areas should be  posted to  prohibit  use, as suggested by  the
Pilchuck  Citizen's  Advisory  Committee.   The  committee   also
suggested  that  graphic  or pictorial warning  signs  for children
be attached to each sign.  Local residents should  be notified by
letter  that  certain areas of  the  tree  farm are  going  to  be
closed for future recreational  use until further notice.
Cultural Resources

     Appendix  E  of  this  EIS presents  correspondence with  the
State   of   Washington  Office   of   Archaeology   and   Historic
Preservation regarding  need  for a cultural  resources  survey of
the  proposed  sludge lagoon  site  and sludge  application  areas.
The University of Washington Office  of  Public Archaeology is in
the process of conducting appropriate site  surveys,  which will
be completed for the Draft EIS.
                              154

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Public Health

     Description of Existing Environment.  A considerable amount
of study of  the health effects of  sludge  application,  handling
and beneficial  reuse  has been completed since  the  early 1970s.
Particular attention has been given  to  the  effects  of sludge on
production of  food  chain crops and production  of crops for use
as animal  feed.  Results  of many  of  these  studies have  been
presented in the earlier portion  of  Chapter 3  and  in Appendix A
of this EIS.

     Assessment  of  Impacts.   The  application  of  sludge  to
forestland would result in exposure  of  site workers and others
in the  area to miciobial pathogens,  heavy metals  and organic
chemicals.   Transmission  routes  from the environment  to humans
typically -may   involve:  inhalation  of  aerosols,  ingestion  or
physical contact with contaminated groundwater or surface water,
ingestion of contaminated plants or animals or soil  by children,
and  physical contact  with  sludge  handling or a  contaminated
area.

     Microbial  Pathogens —  Microbial pathogens  found  in sludge
include bacteria, viruses  and parasites.  Figure 3-10  shows the
possible microbial  transmission  routes  from forest  application
to humans.   Aerosols  are typically  transmitted to humans  by
inhalation,   ingestion,  or deposition  in the  throat or lungs.
Types of bacteria found in Metro sludge include total coliforms,
fecal coliforms, fecal streptococcus, salmonellae,  shingella and
Yersinia (Metro 1983c).  A detailed description of  each of these
bacteria and their occurrence in sludge is found in  Appendix A.

     Several  major  factors  affect  the  survival   of  enteric
bacteria:  moisture content and moisture holding capacity of the
soil;   soil  temperature;   soil  pH;   sludge   organic   matter;
antagonism from soil  microflora,  especially actinomycetes;  and
sunlight (Sagik et al. in Bittbn et al.  .1980) .

     In  general,  bacteria does not survive well  in dry,  warm
soils with  high levels  of  competing  biota and pH below  6.5.
Higher bacteria die-off rates occur in soils exposed to sunlight
than  occur  in  shaded soils.   The  role of organic matter  in
bacteria survival  is  not  entirely  known;  Mullmann and Litsky
(1951)  indicated  that  organic   content from   sludge  enhances
bacteria survival  whereas Van  Donsel  et  al.   (1967)  indicated
that  organic matter plays only  a minor role  when  compared  to
other factors.   Temperature,  moisture and  organic nutrients  in
proper  environmental  conditions  may  stimulate salmonella  and
shigella bacteria growth after the  initial  die-off  (Akin et al.
in Sagik and Sorber 1978) .

     The exact  length of time bacteria survive  in the soil after
sludge application is not  known.  Research  at  a sludge disposal
site   operated  by the East  Bay  Municipal  Utility   District  in
Solano  County,  California,  found  significant  numbers  of total
and   fecal   coliform,   fecal   streptococci,    salmonellae   and
                               155

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               Figure 3-1Q.  Possible Pathways of Microbial Transport Out of
                           Sludge in a Silviculture Application
                                     Digested Sludge

                                           v
                        Application (Spray)
              Surface<—
              Runoff
Trees, Undergrowth, Soil, Litter Layer
Animals
Insects
                                                                                         (Vectors)
                                    Sub-Surface Soil
                                       Groundwater  |
                   Figure 3-11.  Pathways of Metals Transport From Sludge
                              in a Silvicultural Application
                                            Digested Sludge


                                               V
                                            Spray Applicati
Surface | *—Surface^-)  Trees, Undergrowth, Soil, Litter
Water       Runoff   J—'	
Fish
                  Subsoil
                                      Groundwater
                                                                    Insects
            Figure 3-12.  Pathways for Organic Toxicant Transport From Sludge to
                  Bwironmental Compartments in Silviculture Application
                                           Sludge


                                             w
                                        Application-
                                  Soil-Trees-Litter-Shrubs
                                                                      Volatization
                                                                                Condensation off Site
                                                                                water, soil, food crops
   SOURCE:  Metro 1982c.
                                              156

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shigellae  up  to 7 months  after sludge application  to row crop
test plots and irrigated and dryland pastures.  Certain bacteria
species, such as mycobacteria, have survived for long  periods in
the  soil  (150 days to  15  months)  even under  dry environmental
conditions (Sagik et al. in Bitton et al. 1980).  Experiments at
Pack Forest, near Eatonville, Washington, found that the initial
die-off  of fecal  coliform bacteria  was  rapid  and  only  about
1 percent  survived after  45  days.   According  to  Edmonds   (in
Sopper and Kerr  1979),  the bacterial after-growth survival rate
in  forest  applications  is  1  percent   after  225  days.   The
bacterial  survival  pattern   apparently   follows  a  declining
cyclical series  of die-offs and after growths  (Sopper and Kerr
1977) .

     The levels  of bacteria  concentrations  normally required to
cause  infection  and .diseases  in humans  vary  with bacteria
species and  human health  conditions.  However,  generally large
numbers of  these organism are required to  cause  infection (see
Table 3-18 for an example  using salmonellosis).

     A  variety  of  viruses  may be  found  in sludge  including
polioviruses,   coxsackie   viruses  A    and   B,   echoviruses,
adenoviruses,  and  reoviruses.   During Metro's  intensive sludge
monitoring study a mean of  69 enteric viruses  per 100  g (wet
weight) of West Point  undigested  sludge were  isolated.   After
anaerobic  digestion  the  concentration  of  enteric  viruses  was
reduced  to a mean  of  nine  viruses per 100  g  (wet weight)  .
Calculations  based  on  the  total  volume  of  sludge  treated
indicated  a  98  percent reduction  of  viruses during  anaerobic
digestion and dewatering (Metro unpublished data).

     Survival of viruses  in soils is influenced  by  many of the
same  factors  that  affect  bacteria,   although  little  direct
evidence   supports    viral   inactivation    by    antagonistic
microorganisms   (Sagik  et  al.  in  Bitton  et al.   1980).   The
ability of viruses  to  be  adsorbed onto solids in  the  soil also
influences  survival  rates (Metro  Sludge Intensive  Monitoring
Report 1982).  Bagdasarjan (1964) working with a wide variety of
human enteroviruses, including polio viruses, coxsackie viruses,
and  echo viruses,  reported survival times ranging  from 110-170
days at a soil pH of 7.5 and a temperature of 3°C-10°C (Sagik et
al. iri Sopper and Kerr 1979) .

     The ability of viruses to  attach to  soil particles depends
upon   the   pH   of  the   water/soil   environment,  the   ionic
composition, soil saturation, soil type,  and to some degree, the
type of virus.  Virus adsorption is rapid at pH values less than
7.5  and  optimal at pH  5.5-6.5.   The higher  the pH  level,  the
lower the virus adsorption rate.

     Viruses  adsorb  readily  to soils with  high  clay or  silt
contents and poorly to sandy soils.  Both the type and strain of
virus will  affect rates of  adsorption  (Metro  Sludge  Intensive
Monitoring Report 1983c).
                              157

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tn
oo
                     Table 3-18. Quantities Which Must be Consumed at One Time to Result in Salmonellosis

                             and the Time Required for an Average Adult to Consume that Quantity

Aerosols
Sludge- soil-litter
Surface water
Groundwater
During and Bmediately
Application
Quantity1
>1,000,OOOM3
7-70 Ibs
88 to >880 gal
>880 gal
Following
Time2
137 yrs
3
176 days to
>4.8 yrs
>4.8 yrs
Three Months After
Application
Quantity1
NA1*
>70 Ibs
>880 gal
>880 gal
Time
NA"
3
>4.8
>4.8
2


yrs
yrs
              NOTES:  1Quantity of air, sludge/soil or water which must be consumed at one time to result in
                       intake of minimum infectious dose.


                      2Time required for an average adult to consume the given quantity.  Adults normally consume
                       one-half gallon of water and 20M-^ of air daily.


                      3It is not expected that anyone will consume soil from the demonstration area.


                      ''Aerosols are. only of concern during application.


                      All data are currently being reviewed and are subject to change.


              SOURCE:   Metro 1983a.

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     The  levels  of  virus concentrations  normally  required to
cause infection  and  diseases in humans  vary depending on virus
species  and human  health  conditions  (see  Table  3-19  for an
example using enterovirus infection).

     Types  of   parasites  found   in   sludge   include  Ascaris
lumbricoides, Giardia  lamblia,  coccidia and other helminths.  A
detailed description of these parasites and  their levels in West
Point and Renton sludge is found in Appendix A.

     Sludges often  contain eggs  and  cysts, the  most resistant
stages  of  parasites.   The survival of these eggs  and cysts in
the  soil  depends  on  such   factors   as  soil  type,  moisture,
temperature, pH, types  and number  of parasites, land  topography
climatic conditions,  and  subsequent land use  (Little in Bitton
et al.  1980; Metro 1982).

     Ascaris eggs  are generally  the  most resistant  to various
environmental conditions  and have  remained  viable in the soil
for 15  years.  Trichuris eggs have  also been reported  to survive
for several years in the soil (Little in Bitton et al. 1980).

     The levels  of parasite  concentrations  normally required to
cause  infection  and   diseases  in  humans vary depending  upon
parasite  species and  human   health characteristics  (see  Table
3-20 for an example using ascaris/giardia infection).

     Trace Metals —  Trace metals  in  sludge of greatest public
health  concern   are   lead,  copper,  nickel,  zinc,  cadmium  and
molybdenum  (Lee  and  Jones  in  Sagik  and Sorber  1978; Pilchuck
Citizen's Advisory Committee Minutes October 1982).  Figure 3-11
shows the  possible  heavy metal transmission routes  from forest
sludge  application to humans  (Metro 1983e).

     West  Point  and  Renton   sludge contains  arsenic, cadmium,
chromium, copper, lead,  mercury,  nickel and zinc.   Other heavy
metals,  barium  boron,  molybdenum,  selenium  and  silver  are
monitored, but  have  not been detected in either West Point or
Renton  sludge  (Metro  1983a).   A  detailed description of those
metals  and their levels in Metro sludge is found in Appendix A.

     The  detention  and  activity  of  heavy  metals  in  soil  is
affected by  soil pH,  organic matter  content,  clay  content, and
applied sludge concentration  levels.   A detailed description of
heavy metal  movement  and  concentration levels at  the Pilchuck
demonstration sites is given in the soils section and Appendix B
of the  EIS.   Certain heavy metals  (lead,  mercury,  chromium and
silver)  are insoluble  elements  which  are not easily transported
through  the  soil  or  absorbed  by  plants.   Other  heavy metals
(zinc,  copper, nickel, boron, cadmium  and  arsenic)  are known to
cause phytotoxicity in plants if applied in excessive  amounts.

     The levels  of heavy  metal  concentrations  normally required
to  cause human  health  problems  vary  depending  upon  type  of
metal,  type  of  consumption,  and  human health characteristics
(see Table 3-21   for an example using cadmium).


                              159

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               Table 3-15.  Quantities Which Must be Consumed at One Time to Result in Enterovirus Infection
                            and the Time Required for an Average Adult to Consume that Quantity
During and Inmediately
Following Application

Aerosols
Sludge-soil-litter
Surface water
Groundwater
Quantity1
>400M3
0.1-1 Ib
400 gal
>400 gal
Time2
>20 days
3
2.2 yrs
>2.2 yrs
Three Months After
Application
Quantity1
NA
1 Ib
>400 gal
>400 gal
Time2
NA
3
>2.2 yrs
>2.2 yrs
One Year After
Application
Quantity1 Time2
NA NA
>1 Ib 3
>400 gal >2.2 yrs
>400 gal >2.2 yrs
o
        NOTES:  1Quantity of air, sludge/soil or water which must be consumed at one time to result in intake of
                 minimum infectious dose.

                2Time required for an average adult to consume the given quantity.  Adults normally consume one-half
                 gallon of water and 20M  of air daily.

                3It is not expected that anyone will consume soil from the demonstration site.

                All data are currently being reviewed and are subject to change.


        SOURCE:  Metro 1983e.

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               Table 3-20. Quantities Which Must be Consumed at One Tims to Result in Ascaris/Giardia Infection
                              and the Time Required for an Average Adult to Consume that Quantity
CTl
               Aerosols
               Sludge-soil-litter
               Surface water
               Groundwater
                                         During and Inmediately Following
                                                   Application
                                             Three Months After
                                                Application

ASCARIS
Aerosols
Sludge-soil-litter
Surface water
Groundwater
Quantity1

No data1*
>.25 lb/4 oz
>100 gal
>100 gal
Time2 Quantity1

NA
3 >.25 Ib
>200 days >100 gal
>200 days >100 gal
Time2


3
>200 days
>200 days
GIARDIA
No data4

>2.2-5.5 Ibs

>1,000-2,500 gal

>1,000-2,500 gal
>5.5-13.7 yrs

>5.5-13.7 yrs
No data1*

>2.2-5.5 Ibs

>1,000-2,500 gal

>1,000-2,500 gal
>5.5-13.7 yrs

>5.5-13.7 yrs
               NOTES:   •'•Quantity of air, sludge/soil or water which must be consumed at one time to result in
                        intake of minimum infectious dose.

                        2Time required for an average adult to consume the given quantity.  Adults normally
                        consume one-half gallon of water and 20M^ of air daily.

                        3It is not expected that anyone will consume soil from the demonstration area.

                        "*No data exist for parasites in aerosols but, based on low levels in Metro sludge, no
                        illness would be expected.

                       All data are currently being reviewed and are subject to change.

               SOURCE:  Metro 1983e.

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             Table 3-21.   Daily Human Consumption Necessary to Cause Health Problems
                                        from Cadmium or Lead
Substance
Sludge-soil-litter (3)
Sludge/Soil Plow Layer (4)
Tree Farm Soil (5)
Surface water
Groundwater
Edible forest undergrowth
(trailing blackberry)
Deer liver (sludge area)
           (unsludged area;
Deer kidney (sludge area)
Cadmium
Quantity ( 1)
0.004 Ibs.
0.02 Ibs.
0.04 Ibs.
>80 gal.
^80 gal.
0.26 Ibs.
0.07 Ibs.
0.17 Ibs.
0.01 Ibs
) 0.02 Ibs.
Multipl
Normal
(6)
(6)
(6)
> 160
,>I60

(7)
(7)
(7)
(7)
e of
Consumption









                                                                  Lead
 Quantity  (2)
 0.001  Ibs.
 0.007  Ibs.
 0.016  Ibs.
;>40  gal.
;>40  gal.
 unlimited

 0. 18  Ibs.
 0.83  Ibs.
 0.11  Ibs.
 0. 18  Ibs.
                                                                                 Multiple  of
                                                                                 Normal  Consumption
                                                                                 (6)
                                                                                 (6)
                                                                                 (6;
                                                                               >80
                                                                               p-80
                                                                                 infinite

                                                                                 (7;
                                                                                 (7)
                                                                                 (7)
                                                                                 (7)
(1)
(2)

(3)

(4)

(5)
(6)
(7)
     Cd toxicity based on 200 ug daily ingestion from all sources for 50 years
     Pb toxicity based on 150 ug daily ingestion by children over an undetermined period.  Adults can safely
     consume twice as much lead as children.
                   inch of sludge  mixed  with
     Assumes a mixture of ]  part sludge to 2 parts soil on a dry weight basis or
     1/4 inch of soil.
     Assumes a mixture of 1  part sludge to 30 parts soil on a dry weight basis or  1 inch of sludge mixed with
     4 inches of soil.
     Based on 1.6 mg/kg Cd and 21 mg/kg Pb avg. measured content in soilo^- PAA^*tW T«-««
     It is not expected that anyone will consume soil from the demonstration area.
     Cannot calculate because normal intake not known.
SOURCE:  1983e.

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     Organic  Compounds  —  The  two major  groups  of  organic
compounds in sludge of  public  health concern are organochlorine
pesticides   and   polyaromatic   hydrocarbons.    The   possible
transmission  routes  of organic  compounds  from forest  sludge
application to humans are shown in Figure 3-12.

     West Point and Renton sludges contain no detectable amounts
of   chlordane,   dieldrin,   DDT,    aldrin,   endrin,   lindane,
methoxychlor,  toxaphene, 2,4-D and  2,4,5-TP  (silvex).   However,
polychlorinated biphenyls (PCBs) are found in low concentrations
in both West Point and Renton  sludges (Metro 1983a).  A detailed
description  of  these  organic compounds  and  their levels  in
sludge is found in Appendix A.

     The persistence  and decomposition of organic  compounds in
soil  is  influenced  by  such  factors  as  photodecomposition,
chemical  and   microbiological  decomposition, detoxification  by
crop plants or weeds  and soil  characteristics.   The ability of
soils to adsorb organic  pesticides  could  also  help  to decompose
these compounds,  by  concentrating  the  compounds near  the  soil
surface  where  microbial  activity occurs.   In  many instances,
however, organic  compounds  are not  decomposed  in the  soil but
transferred and  diluted.   Such transfer  and dilution  processes
include  volatilization, movement into  and  out of plants  by
adsorption and exudation,  retention by crops and weeds,  runoff
into  streams   and  lakes,  movement   downward into  the  soil  in
percolating water and  upward   from  lower depths by  capillary
flow, and adsorption  and inactivation by  soil  constituents  (EPA
1980b).    A detailed  description  of organic  compounds,  their.
movement, and  their concentration levels  at  demonstration sites
is given in the soils section of this EIS.

     Little information is available on  the amount of organic
compounds  taken  up  by plants  in  the   food  chain  and  their
potential toxicity  to humans  (EPA  1980b).   The  most  important
factors controlling organic compound uptake  by  plants  are water
solubility; solute  concentration;  size and  polarity of organic
compound  molecules;   and soil  organic  content, pH,  clay  and
microbial  activity.   Climatic  factors  also play an  important
role (Pahren et al. 1979) .

     The  levels  of  organic   compound  concentrations  normally
required to  cause human health problems varies  depending  upon
type of  organic compound and  human health  characteristics (an
example using PCBs is shown in Table 3-22) .

     Exposure   of    Workers    and   the   Public   to   Sludge
Contaminants —  Workers transporting,  handling,  and  spraying
sludge  onto  the  application  sites  would receive the  greatest
exposure  to  the  aforementioned  contaminants.   The  greatest
exposure to sludge would be during  transfer  from haul  trucks to
the basin, from the basin to the  nursing  vehicle or application
vehicle, and during any equipment cleanup at the sludge storage
facilities.
                             163

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        Table 3-22.  Quantities Which Can be Consumed on a Continuous Basis
                   Without Exceeding Standards or Criteria for PCBs
Point of
Transmission
Surface water
Edible plants
Animal meat
Groundwater
Quantity
Comments
Aerosols
Soil
Unknown
15 g (0.6 oz)
No data
Used 1.2 ppm PCBs
as standard

in soil and .3 ppm in food
Not
quantifiable
Unlimited



Unknown1


Unknown
7.5 g soil equivalent to eating one egg with
.3 ppm PCBs  (Kaldriko and Nelson 1979)

Detection limit is above reconmended EPA
criteria.  Based on work of Kaldriko and
Nelson 1979, surface erosion and subsequent
surface water contamination should be unde-
tectable.

Sludge maxijnum PCBs levels are four times
lower than EPA-recommended PCB concentrations
for agricultural use.

Deer fat tissue could potentially accumulate
PCBs but deer fat is not usually eaten by hunters.

Detection limit is above EPA-recamended
criteria.  However, no detectable leaching of
PCBs to groundwater is anticipated.
        fed a diet which has 11 percent sludge with a PCBs content higher than
 Metro sludge did not accumulate PCBs in body fat higher than FDA standards
  (Baxter et al. 1980).

 Note:  All data are currently being reviewed and are subject to change.
 SOURCE:  Metro 1983e.
                                           164

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     The sludge to which the workers would be exposed would have
gone through an anaerobic digestion process, which  is considered
by  EPA  as  a  "process  to  significantly  reduce  pathogens."
Anaerobic  digestion  at  Metro's  West  Point  Treatment  Plant
reduces  pathogens  by  approximately  85-90 percent.   There have
been  no illness  incidents  to  date  affecting  any of Metro's
hauling contractors.

     Because the sludge application vehicle would have  a remote-
-control powered cannon-type  sprayer,  the vehicle operator would
be protected from exposure to the sludge by the enclosed cab.

     Because  the  application  sites  would  be  closed  to public
access  during  application and  for  a year  thereafter,  very few
people  would  likely be exposed  directly  to  the sludge.  Access
would  be  controlled  by  a  locked  gate  and   signs  along  the
perimeter  of  the   site,   in   addition  to  the  steep  cliffs
surrounding much  of the  east,   south and  west portions  of the
sites.

     Metro  (1983d)  proposes  to  continue  to keep the site closed
to  public  use for  1  year  following sludge  application.   Data
suggest that 1 year is  sufficient  time  to achieve die-off for a
majority of  the  microbial organisms.   Insufficient data exist,
however,  regarding  the longevity  or  concentrations   of  trace
metals  in  soils  and  uptake  by edible  mushrooms  and  berries.
Research on those  subjects  is  scheduled to  continue  at  Pack
Forest  and to be  a  part of  future studies  conducted by  the
University of Washington on the  Pilchuck demonstration  sites.

     The potential  contaminant  pathways  through groundwater and
surface  water were  discussed  in  previous  sections  of  this
chapter and will  not  be repeated here.   Because of the isolated
nature  of  the site  and the movement  of groundwater  away  from
private   drinking   wells,   the  likelihood   of   groundwater
contamination representing a public health hazard is remote.

     Aerosols  generated  during sludge  spraying  and   from  the
surface  of  sludge  applied  to soil  represent  one   potential
pathway of exposure to sludge  pathogens.   Few studies   have been
conducted  on  the   production  of  aerosols   from  the  spray
application of sludge.  Although Harding et al. (1980)   evaluated
aerosol  production  from  sludge applied  by tank  truck and  by
spray  irrigation,   a majority   of  the   information on aerosol
production has related  to wastewater  application  (Sorber et al.
in  Sopper  and Kerr 1979; EPA  1981c) .    Harding  et al.  (1980)
found   that  sludge   aerosol    production   using  tank   truck
application was intermittent and difficult to  detect  because of
the constant movement  of the application  vehicle.   The Harding
study concluded that aerosols are generated and transported from
the sprayed  area  but  that  the  transport  is limited.   No  data
were provided regarding the  percent  of  aerosolization   of sludge
applied  by truck;  however,  data  from  fixed-head  sludge  spray
sites   showed   aerosolization   to   be    low,   ranging   from
0.00070-0.037 percent  as  compared to  aerosolization  of  spray
applied wastewater  which has been  shown to range  from 0.1-1.5
percent  (EPA 1981c)  .

                              165

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     The distance  that aerosols move  off-site would  depend on
such  factors  as wind  speed  and  direction,  relative  humidity,
interference  caused by  vegetation,  solar  radiation,  and  air
temperature.  Harding et al.  (1980)  concluded that the transport
of and  exposure  to aerosols can be minimized by  initiating the
following practices:

     o  Creation of a buffer zone around the application site.
     o  Application of sludge during daylight hours when periods
        of  high  solar  radiation and  low humidity  would  reduce
        concentrations of aerosols.
     o  Limiting   spraying   during   periods  of   high   wind
        conditions.

     Metro  has  already  established a  buffer zone  between  the
application site  and  the  residential  area  to the  north.   The
sludge operation plan to be developed by Metro would specify the
allowable   conditions  for   sludge   application  (Sasser  pers.
comm.).

     The  distances  of  aerosol  drift  and  likely  pathogenic
concentrations from  the  demonstration  site  cannot be determined
without  specific  monitoring;  however,  given  the  likely  small
percent of  aerosolization (less than 0.05 percent) and the width
of  the  buffer zone  on the north side  of the  application  area
(500  feet), the  impacts  associated  with aerosol drift resulting
from  this  project are projected  to be  minor.  The  effects of
forest  canopy on  aerosol  production   and  drift  are not  well
understood  (Edmonds and Mayer _iri Bledsoe 1981) .

     Proposed  Pathogen  Monitoring  Program  — A  part  of  the
Pilchuck  demonstration  project  would   include   an  intensive
monitoring  program.    A  major  Metro  objective of  the  program
would be  to "provide assurance to  local  residents  and agencies
that  potential  contaminants are contained  on the  site  without
jeopardy  to  public health  or  environmental  quality"  (Metro
1982c).   The  proposed program  would  conform with  monitoring
guidelines  identified in DOE's BMPs  (1982a).

     The surface water and  groundwater monitoring programs  were
previously  described  in  the  surface  water  and  groundwater
evaluations  of   the  Pilchuck  project.   In  addition  to  water
quality monitoring,  the  soil and sludge mix  would  be monitored
for bacterial die-off at two locations.

     Prior  to project startup,  Metro  would  need to  receive  a
permit  for land  application  of sludge  from  the Environmental
Health Division of the Snohomish Health District.   Site-specific
information such  as the physical  characteristics  of the  site
(soils,  depth to  groundwater),  sludge  characteristics,  sludge
volume  to  be  applied,  and a  site development map are necessary
components  of permit  application.   Following  permit  approval,
the  Snohomish  Health  District  would  conduct  periodic  site
inspections,  review  all  monthly,  bimonthly   and  quarterly
monitoring  data and  provide  an  annual  review at the end  of  each
annual permit period (Willey pers.  comm.).


                              166

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     Mitigation Measures.  A  number of mitigation  measures for
surface water and groundwater impacts were previously described.
One  additional  measure  should be  considered  to minimize  the
likelihood of impacts caused by aerosol drift:

        o As a general rule,  sludge spraying closest to the
          residential area should be accomplished on days of no
          wind or when the prevailing wind directions is away
          from the residential areas.

With  regard  to  public  use   of  the  site  following  sludge
application, the following measure should be considered:

     o  Results  of  studies  of mushrooms,  edible berries,  and
        wildlife  conducted  at  the  site  should  be  used  to
        determine the  need to  limit  public  activities on  the
        site  to  a   period  longer   than  1  year  after  sludge
        application.

     As a consideration  for  ensuring that sludge is  applied on
the  site   in   a  uniform  and   consistent   manner,   Metro  is
considering the following measures:

     o  Development of site operations procedures.
     o  Development of a procedure  for clearly  delineating unit
        areas designated  for  sludge application  (i.e.,  marking
        boundaries for each truckload of sludge).
                               167

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	Chapter 4
             Coordination
          •Public Participation
            •Scoping Process
•Upcoming Coordination Efforts

-------
                            Chapter 4
                          COORDINATION
                          Introduction

     EPA's procedures  for implementation  of NEPA  require  that
EISs discuss  the  extent and results  of  coordination activities
conducted prior  to publication  of EISs  (40 CFR  6.203) .   This
chapter  describes  the   involvement   of  government  agencies,
interest groups,  and  the public  in general in  determining the
scope and content of this EIS.


                      Public Participation

     Public  participation for  this  EIS  has been  coordinated,
and,  where  possible,   integrated  with  the  full-scale  public
participation program undertaken by Metro in preparing its Draft
Sludge Management  Plan  and the Pilchuck  demonstration project.
Key EIS  public  participation activities to  date  are summarized
below.
Information Brochure

     In  October   1981,   EPA  published  a   brochure   entitled
Municipality of Metropolitan  Seattle  Sludge  Management Program.
This widely-distributed brochure provided background information
on  the  sludge  management plan  being  prepared by  Metro,  listed
and discussed  key issues for the  EIS,  described EPA's  role  in
decision making and  in preparing  the  EIS,  and identified future
public involvement opportunities.  The  brochure  also included a
Notice of  Intent  inviting members of the  public  to  attend the
initial project "kickoff" and scoping meetings.


Scoping Meetings

     Joint  scoping  meetings  were  held by   Metro  and  EPA  in
December 1981.   Metro staff explained the  planning approach and
gave  examples   of   sludge   application  projects   previously
undertaken  by   Metro.    In  addition  to  Metro's  presentation,
presentations  were  made  by  EPA  staff and  the  EIS  consultant
regarding  EPA's  role  in  preparing   the  EIS  and  some  of  the
important issues  to  be  addressed in  the EIS.  A responsiveness
summary was prepared and distributed in April 1982.
                               168

-------
Notice of Intent

     On November  6,  1981 EPA's  Notice of Intent  to  prepare an
EIS was published in the Federal Register.


Preparations to Sludge Advisory Committees

     On February 15 and 16, 1983, the EIS consultant presented a
report on  the EIS to  the Pilchuck Citizens  Advisory Committee
and  to  the Metro Sludge  201  Citizens Advisory  Committee.  The
impacts associated with  the proposed  long range alternative and
the proposed Pilchuck project were identified and discussed.


            Comments and Suggestions Reviewed During
                  Preparation of the Draft EIS

     During  the  course  of  the  Metro  planning  period,  the
Pilchuck  Citizens  Advisory  Committee developed a  list  of 17
concerns  associated  with  Metro's  proposed   sludge  application
project on the Pilchuck Tree Farm.  The  concerns were used as a
"checklist" to ensure that the topics were addressed in the EIS.


                  Upcoming Coordination Efforts

     This  Draft  EIS  has  been  forwarded  to numerous  federal,
state and  local  agencies,  special interest  groups,  and private
citizens  to  act as  both  an  informational  document  and  as an
avenue  to comment on  the proposed  sludge  management  project.
The distribution list  is  shown  in  Appendix G.  The document has
been  forwarded  to  public  libraries  in  the  study area  so that
other concerned residents can review the potential impact of the
project.

     Individuals of groups that wish  to comment  on  the EIS may
forward written comments to:

     U. S. Environmental Protection Agency
     Region 10
     1200 Sixth Avenue
     Seattle, Washington  98101
     Attention:   Kathryn Davidson

     Comments should be sent by May 30, 1983.

     Joint  public  hearings  have  been  scheduled  on  the  Draft
Sludge Management Plan and Draft EIS by Metro and EPA for May 15
and May 17,  1983. Citizens and  agency representatives will have
a chance  to  learn  about the  plan and EIS and to present formal
oral and written testimony.
                              169

-------
     All oral  and written  comments  received  on  the Draft  EIS
will be recorded and responded to  in  a  final  EIS,  which will be
made available  to interested  individuals,  groups  and  agencies
approximately 3 months after the public hearing.
                              170

-------
                      LIST OF EIS PREPARERS
U. S. Environmental Protection Agency - Region 10

     Richard  Thiel,  Chief,  Environmental  Evaluation  Branch;
Seattle, Washington.

     Area  of  EIS  Responsibility.   Coordinates  EIS  preparation
effortswithotherEPARegion  10  environmental  evaluation
functions.


     Daniel   I.   Steinborn,   EIS   Preparation   Coordinator,
Environmental Evaluation Branch; Seattle, Washington.

     Area  of  EIS  Responsibility.   Coordinates  EIS  preparation
efforts for EPA Region 10.


     Kathryn Davidson, Project Monitor, Environmental Evaluation
Branch; Seattle, Washington.

     Area of EIS Responsibility.  Principal monitor and reviewer
of Metro Sludge Management Plan EIS.


Jones  &  Stokes  Associates,  Inc.,  Sacramento,  California  and
Bellevue, Washington:


     Charles  R.  Hazel,  B.S.,  M.S.,  PhD.,  Fisheries  Biology.
Formerly with California Department of Fish and Game as Director
of Water  Pollution  Control  Laboratory,   As  President of Jones &
Stokes  Associates,  has  managed numerous environmental  studies
and  reports  and served  as  expert consultant  in  fisheries  and
water quality ecology.

     Area of EIS Responsibility.  Project management.


     Jonathan  H.   Ives,   B.B.A,  Wildlife  Management;   M.S.,
WildlifeBiology.Asstaff environmental  scientist/manager at
the  Bellevue  office,   responsibilities   are   overall  project
management, coordination of  EIS preparation  team  efforts  and
compilation of EIS.  With Jones & Stokes Associates for the past
8  years  preparing  and  managing  preparation  of  environmental
impact  analyses.    Formerly environmental  planner/manager  for
Anderson-Nichols and' Company, Inc.

     Area  of  EIS  Responsibility.   Project coordinator;  sludge
managementalternatives,public  participation  and  wildlife
impact analysis.


                              171

-------
     Albert  Herson,   B.A.,  and  M.A.,  Psychology;  M.A.,  Urban
Planning.  As  staff  environmental planner, responsibilities are
project   management   and   preparation  of   planning  studies,
specializing  in land  use  planning,   growth  policy  and  public
service  systems.   Formerly water quality planner  for Southern
California   Association  of   Governments.   Member,   American
Institute of Certified Planners  (AICP).

     Area   of   EIS    Responsibility.    Legal,    policy   and
institutional considerations, project  coordination.


     Patricia  Gibbon,  B.S.,  Agriculture  Economics  and  Soil
Science;  M.S.,  Urban  and  Regional  Planning.   Environmental
planner   specializing   in  land  use   and  outdoor  recreation
planning, soil science and natural resource economics.  Formerly
with  Town  of  Tiburon,  California,  Wisconsin  Department  of
Natural Resources and City of Minneapolis.

     Area   of  EIS   Responsibility-    Land  use,   aesthetics,
recreation and public health impact analysis.


     Alice   Godbey,    B.S.,   and  M.S.,   Civil   Engineering.
Environmental engineer specializing in water resources and water
quality.  Formerly with Massachusetts  Institute of Technology as
a research assistant.

     Area of  EIS Responsibility.   Groundwater  and surface water
quality impact analysis.


     Robert  Penman,  B.S.,  Forest   Management;   M.S.,   Forest
Hydrology.  Environmental hydrologist  specializing in forest and
stream hydrology, sediment transport and soil science.  Formerly
with  University  of   Washington  as  a research  assistant  and
Weyerhaeuser Company as a forestry aide.

     Area   of   EIS   Responsibility.    Geology,   soils   and
silviculture impact analysis.


     Brian  Plant,  B.S.,  Conservation and  Resources  Studies.
Environmental  specialist experienced  in  fisheries  and  water
quality.    Formerly   with  John   Muir  Institute  Center   and
University  of  California, Berkeley,  as  a field  and  laboratory
technician.

     Area   of   EIS  Responsibility.   Aquatic  biology   impact
analysis.


     Robert    Sculley,    B.S.,    Zoology;    M.S.,    Ecology-
Environmental  specialist  experienced  in  air quality  and noise
analyses  with emphasis  on   line  source  modeling  and  emission
forecast  development.   With Jones  &  Stokes Associates  for the
past  11  years  preparing  and  managing  environmental  impact
analyses.
                               172

-------
     Area of EIS Responsibility.  Air quality and traffic impact
analysis.


Blazier Engineers:


     Richard Gilmore,  P.E.y B.S,  and M.S.,  Civil  Engineering.
Civil engineerspecializing in sanitary  engineering,  and solid
waste management.

     Area of  EIS Responsibility.   Review of  sludge  management
alternatives and cost-effective analysis.


University of Washington, Office  of Public  Archeology, Seattle,
Washington:


     Hal K.  Kennedy, B.A.,  and  M.A.,  Anthropology.   Experienced
cultural resources researcher with extensive field experience in
the Pacific Northwest.

     Area  of  EIS  Responsibility.   Cultural  resources  impact
assessment.
     Carol Kielusiak, B.A.,  and M.A.,  Anthropology.  Experienced
in  cultural   resource   management  and  field   experience  in.
California and Washington.

     Area  of  EIS  Responsibility.   Cultural  resources  impact
assessment.
The Works, Seattle, Washington:


     Nelda  Levine,  graphic  development  and  preparation  for  a
variety of EISs and architectural projects.

     Area of EIS Responsibility.  Report graphics.
                               173

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174

-------
                      BIBLIOGRAPHY
                       Documents

Akin, E. W.,  W. Jakubowski, J. B. Lucas, and H. R. Pahren.
  1978.  Health hazards associated with wastewater ef-
  fluents and sludge:  microbiological considerations.
  Pp. 9-25 in Bernard P. Sagik, and Charles A. Sorber,
  eds., RisF~assessment and health effects of land appli-
  cation of municipal wastewater and sludges.  Center for
  Applied Research and Technology, San Antonio, TX.

Alexander, M.  1977.  Introduction to soil microbiology.
  2nd ed.  John Wiley, New York.  467 pp.

American Fisheries Society.  1979.  A review of the EPA
  red book:  quality criteria for water.  AFS, Water
  Quality Section, Bethesda, MD.  313 pp.

Andersson, A., and K. 0. Nilsson.  1972.  Enrichment of
  trace elements from sewage sludge fertilizers in soils
  and plants.  Ambio 1:176-179.

Archie, S. G., and M. Smith.  1981.  Survival and growth
  of plantations in sludge-treated soils and older forest
  growth studies.  Pp. 105-114 iri C. S. Bledsoe, ed.,
  Municipal sludge application to Pacific Northwest
  forest lands.  College of Forest Resources, University
  of Washington, Seattle, WA.

Bailey, G. W., and J. L. White.  1970.  Factors influenc-
  ing the adsorption, desorption and movement of pesti-
  cides in soil.  Residue Review 32:29-92.

Beck, J. W.,  and J. E. Davies.  1981.  Medical parasi-
  tology-  C. V. Mosby Company, St. Louis, MO.

Beyer, W. H., R. Chaney, and B. Mulhern.  1982.  Heavy
  metal concentrations in earthworms from soil amended
  with sludge.  J. Environ. Quality 11(3):381-385.

Bledsoe, C. S., and R. L. Zasoski.  1981.  Seedling
  physiology of eight tree species grown in sludge
  amended soils.  Pp. 93-100 in C. S. Bledsoe, ed.,
  Municipal sludge application to Pacific Northwest
  forest lands.  College of Forest Resources, University
  of Washington, Seattle, WA.
                            175

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Board of Natural Resources.  1970.  State of Washington
  rules and regulations relating to protection and res-
  toration of lands disturbed through surface mining.

Brewer, D. W.,  D. W. Cole, and P. Schiess.  1979.  Nitro-
 'gen transformation and leaching associated with waste-
  water irrigation in Douglas fir, poplar, grass, and
  unvegetated systems.  Pp. 19-34 in W. E. Sopper, and S.
  N. Kerr, eds., Utilization of municipal sewage effluent
  and sludge on forest and disturbed land.  Pennsylvania
  State Univ. Press, University Park, PA.

Brooks, -T. J.,  Jr.  1963.  Essentials of medical parasi-
  tology.  Macmillan Co., -New York.

Browning, E.  1961.  Toxicity of industrial metals.
  Butterworths, London.

Burge, W. D., and P. D. Millner.  1980.  Health aspects
  of composting:  primary and secondary pathogens.  Pp.
  245-264 in G. Bitton, B. L. Damron, G. T. Edds, and
  J. M. Davidson, eds., Sludge-health risks of land ap-
  plication.  Ann Arbor Science, Ann Arbor, MI.

Burge, W. D., W. N. Cramer, and E. Epstein.  1978.  De-
  struction of pathogens in sewage sludge by composting.
  Transactions of the American Society of Agricultural
  Engineers 21 (3):510-514.

Burnett, George, and George Schuster.  1973.  Pathogenic
  microbiology.  C. V. Mosby Company, St. Louis, MO.

Chaney, R. L.  1973.  Crop and food chain effects of
  toxic elements in sludges and effluents.  Pp. 129-142
  in Recycling municipal sludges and effluents on land.
  National Association of State Universities and Land
  Grant Colleges, Washington, D. C.

           1980.  Health risks associated with toxic
  metals in municipal sludge.  Pp. 59-84 in G.•Bitton,
  B. L. Damron, G. T. Edds, and J. M. Davidson,  eds.,
  Sludge-health risks of land application.  Ann Arbor
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Clark, D. R., Jr.  1979.  Lead concentrations:  bats vs.
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                           176

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Cole, D. W.,  and D. W. Johnson.  1979.  The cycling of
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                            177

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                            178

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Hubbard, S.  1981.  Seattle Metro sludge management op-
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                            179

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Mayer, K. P.  1980.  Decomposition of dewatered sewage
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                           180

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             1983a.   Draft long-range sludge management
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                           181

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                           182

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                            183

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                            184

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                           185

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                           186

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Uchida, B.  January,  1983.  Process Control Supervisor,
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                           187

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Willey, A.  January, 1983.  Environmental Health
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Zasoski, R.  December, 1982.  Professor, University of
  Washington.
                            188

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    Appendix A
Public Health

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                           Appendix A
                          PUBLIC HEALTH
                          Introduction

     This appendix has been  developed  to provide the EIS reader
with a  brief  technical overview of the  nature  of trace metals,
bacteria, viruses, parasites, and organic toxicants monitored as
a part  of Metro's  sludge  intensive monitoring program conducted
at  the  West  Point  and  Renton treatment  plants  from May  27
through  September 2,  1981  and as part of  Metro's continuous
monitoring program.

     Not  all  of  the  constituents  mentioned  herein occur  in
Metro's  sludge.  For  those nondetectable constituents:   barium,
boron, molydenum, selenium, and silver, only a brief description
is presented.  Information on the occurrence within Metro sludge
is  provided where  known.   Further information  on  effects  on
humans, plants, and animals, where applicable, is presented as a
result of literature review.
                          Trace Metals


Arsenic

     Arsenic  is  widely  distributed  in  nature  in  two  forms:
elemental  arsenic,  which is a  brittle  metal,  and  as  arsenides
and arsenosulfides of heavy metals.   Arsenic  is not regarded as
an essential  element  for human metabolism, but as  a stimulant.
The   normal  human   adult's   daily   intake   of   arsenic   is
approximately  0.2-1  mg   (Venugopal   and  Luckey  1978).   About
four-fifths of this is stored  and  widely  distributed within the
tissues.

     Acute  arsenic  poisoning  can occur  in  humans when  large
quantities  are   ingested.   Arsenic  poisoning  is  a  general
protoplasmic poison which  acts upon  various  ferment processes,
especially  in  the phosphates.   Eventually oxidation and tissue
respiration diminishes  to low  levels.   Arsenic  poisoning  also
has  a   paralytic  action  on  smooth  muscles  and  leads  to
hemorrhage.

     Chronic symptoms of arsenic  poisoning can occur  in humans
who inhale  arsenic  dust.  The  chronic symptoms include  loss of
weight,  gastrointestinal disturbances,  skin  eruptions,  loss of
hair,  and peripheral neuritis (Browning 1961).
                              189

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     Nationwide,  arsenic  has  been  found  in  sludge  at  levels
ranging from 1.1-230 mg/kg dry weight with a median value around
10 mg/kg  (Chaney  1980) .   Digested dewatered  sludge  measured at
Metro's West Point plant from May 1981 to May 1982, was found to
have  a mean  value  of  14  mg/kg  of arsenic  while   raw,  waste
activated sludge  from the  Renton's  treatment plant  had  a mean
value of 6.4 mg/kg of arsenic (Metro 1983a).  The primary source
of  arsenic  in Metro  sludge is  from industries  (Cochran pers.
comm.).   The  human  health  hazards   associated  with  sludge
containing  arsenic  have  not been  well studied  (Lindsay 1973) .
Pahren et al.  (1989)  concluded  that  arsenic is of little threat
to humans because of the low levels encountered in most sludges,
its relatively insoluble nature and its ability to strongly bond
to clays.

     The degree of arsenic phytotoxicity depends upon whether or
not plants  are  growing  on clay  or sandy soils.   In  clay soils,
arsenic in the chemical form of arsenate is held strongly by the
clay fraction and is not readily available for plant uptake.  In
sandy  soils, arsenic  is not strongly held  and phytotoxicity can
occur  if excessive  amounts are applied  to  those   soils   (EPA
1976a).  With the exception of root crops,  arsenic phytotoxicity
generally causes  reductions in  crop yields  before  appreciable
amounts  accumulate  in the  edible plant  tissues.   Arsenic  can
accumulate in the edible peel of root crops as the soil level of
arsenic  increases.   Bioaccumulation   in   the  food  chain  is
unlikely to  occur  from  arsenic  accumulation because  of  the low
levels generally found in sludge.

     Domestic  animals are  similarly protected against  arsenic
accumulation because  of  the low levels found  in  sludge   (Chaney
in Bitton et al. 1980) .
Barium

     Barium occurs in nature in a wide variety of forms:  as the
sulfate  barite  or  heavy   spar   (BaS04),   as  the  carbonate,
witherite (BaC03) and in zinc and iron ores.  Most of the barium
in  the  human  body is  stored in muscle tissue,  bones,  and lung
tissue  (Venugopal and Luckey 1978).

     Acute  barium poisoning can  occur  in  humans  when  large
quantities of soluble barium salts are ingested  (Browning 1961) .
Symptoms  of acute barium poisoning  are excessive  salivation,
vomiting, colic, muscular paralysis and paralysis of the central
nervous system.

     Chronic symptoms  of barium poisoning  are  less  severe but
similar in  nature  to the effects of  acute  poisoning (Venugopal
and Luckey  1978).  Inhalation of finely  ground  barium sulphate
(BaS04)  can cause a  chronic  respiratory  infection,  baritosis or
benign  pneumoconiosis.   Baritosis  causes  no  specific  symptoms
and does  not  lead  to tuberculosis.   It has  been  demonstrated
                              190

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that baritosis  often  stops  when  the individual  is  no  longer
exposed to barium sulphate dust (Browning 1961).

     Neither  West   Point's   "digested,  dewatered   sludge  nor
Renton's raw, waste  activated  sludge  was tested for barium from
May 1981 to May 1982 (Metro 1983a) .
Boron

     Boron is widely distributed in nature as borax, colemanite,
boronatrocalcite,  and  boracite.   The normal  human  adult  diet
contains between 10-20 mg  of boron per day.  Much  of the boron
found in the  human body is  ingested  from fruits and vegetables
(Browning 1961) .

     Acute  boron  poisoning  can  occur   in  humans  when  large
quantities of boron hydrides and boranes  are inhaled.  Symptoms
of acute boron poisoning include muscular cramps,  shortness of
breath,   exhaustion,  mental  confusion, headaches,   and  nervous
system problems.

     Chronic symptoms of boron poisoning can occur in humans who
absorb  small  amounts  of boric  acid  over  long periods  of time.
This  can  lead   to mild  gastrointestinal  irritation,  nausea,
vomiting, and rash (Browning 1961).

     Boron has been found in sludge throughout the United States
at levels  ranging  from 4-1,000  mg/kg dry weight with  a median
value around 33   mg/kg  (Chaney  1980).   Neither  West  Point's
digested,  dewatered  sludge  nor Renton's  raw,   waste  activated
sludge  was  tested  for boron from May 1981  to   May  1982 (Metro
1983a).

     When  boron  is applied  to  croplands  in excessive  amounts
phytoxicity in plants  occurs.   Because boron is so phytotoxic,
severe  yield  reduction occurs  in most plants  before boron is
appreciably increased in edible  plant tissue.   The  quantity and
concentration of boron entering the  food chain are  limited by
this natural process  (Chaney in  Bitton et al.  1980).  Also, the
level of  boron  accumulation  in  the soil  is  relatively  low
because  of the low amounts of boron in sludge (Chaney 1980).
Cadmium

     Cadmium is a soft, white,  easily fusible metal that occurs
in  nature  chiefly  as  a   sulfide   salt.    It  is  frequently
associated with zinc and lead  ores.   This  metal causes the most
concern to human health when sludge is applied to land.
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     The major  sources  of cadmium intake  in  humans  are through
ingesting   food   and  drinking   water  that   contain  various
concentration   levels,   inhaling  ambient  air,  and  smoking
cigarettes.   Data  have  shown that  0.1-0.2 mg  of  cadmium  are
inhaled for each cigarette  smoked.   Thus,  smoking 20 cigarettes
per  day  would  result   in   inhaling   about  3  mg  of  cadmium.
Although  the  majority of  total   cadmium  intake is  through  the
gastrointestinal  route,  only  4-5 percent is  absorbed by  the
body.  Forty-six  percent of  the  body's  cadmium  is  absorbed by
inhalation  (Pahren  et al.  1979)  .  Once  absorbed  into the body
cadmium  is stored  largely  in  the  kidneys  and  liver and  is
excreted at an extremely  slow rate  (EPA  1976b).  Cadmium levels
tend to increase  in the kidney from birth to approximately age
50 and then to decrease thereafter.   The median concentration of
cadmium in kidneys  is  32 mg/g wet  weight.  Smokers  have been
shown to have a cadmium level 50  percent higher than nonsmokers.
Urine is considered to be the major  means  for cadmium excretion
(Pahren et al. 1979).

     The human  kidney is the  primary  target organ  for chronic
health  effects  from  cadmium.  Renal  tubular  dysfunction  will
begin to  occur  in an individual   when  the  cadmium concentration
in  the renal cortex  reaches approximately 200-300  mg/g  wet
weight  (Naylor  and Loehr  1981).   Renal   damage  from  cadmium
results in an abundance  of  low molecular weight serum proteins,
especially B2-microglobulin in urine.  Continued exposure beyond
the threshold for protein uria results  in proportionally greater
B2-microglobulin excretion.   Whether  the earliest effects on the
kidney are reversible when  the  cadmium  level decreases is  not
known.   Also  still unknown  is   the  clinical  significance  of
minimal renal tubular damage  (Pahren  et al. 1979).

     Itai-itai  is  another  disease   which  results   from  high
concentrations of cadmium in  drinking  water and diet.   Symptoms
of  this  disease are  the   fracturing of bones  and  skeletal
deformations  due  to softening of bone tissue.   These symptoms
of   skeletal   deformation   are   caused   by  impaired  calcium
metabolism, calcium deficiency and  impaired  regulation of  the
calcium-phosphorus  balances  in the  body.   Itai-itai  disease is
the most  severe  manifestation of cadmium  poisoning  (Naylor  and
Loehr 1981) .

     The U. S. Food and  Drug Administration (FDA)  has estimated
the average dietary  intake of cadmium is 39 mg/day-  This figure
represents  the  mean of  the  median  levels  of cadmium  found  in
foods during  the years  1968 to   1974  (Naylor and Loehr 1981).
The level of cadmium in foods varies.

     In  1972,  a   joint Food  and  Agricultural  Organization
(FAO)-World Health  Organization   (WHO)  Expert Committee  on Food
Additives  established  a provisional  tolerable  dietary  daily
intake  of 57-71  mg/day  of  cadmium.   This figures  represents
about 1 mg/day per  kilogram  of body  weight.   Since 1972 the  EPA
has established  a maximum acceptable  dietary intake  of cadmium
of 70 mg/day.
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     Various metabolic models have  been  used to project cadmium
exposure  levels  necessary  to  produce  critical  concentration
levels in the kidney.  Using a model developed by Kjellstrom and
Nordberg, the EPA  found  that the  renal cortex concentrations in
nonsmokers would reach  200 mg/g wet weight  in  50  years with an
average  daily  dietary intake of  440  mg of  cadmium  (Naylor and
Loehr  1981).   Smokers   would  reach   the  critical  level  with
proportionately less  intake by  ingestion  (Pahren  et al. 1979).
Sampling  of digested,   dewatered  sludge  from  the  West  Point
treatment plant has shown a mean value of 46 mg/kg cadmium while
Renton's raw,  waste  activated sludge  had  a mean  value of 19.4
mg/kg  (Metro  1983a).   Cadmium  in  sludge comes  from street and
highway  runoff,  industrial  sources,  and from  the water supply
system (Hilderbrand pers. comm.).

     The EPA has  established  limits   on  the amount  of cadmium
that may be applied to food chain crops for human consumption or
for crops produced for animal feed.  The most restrictive annual
application  rates  are for  leafy  green vegetables,  root crops,
and  tobacco.   No  more  than  0.5  kg/ha  (0.45  Ibs/acre) may  be
applied  annually for  production of  those crops.  For other food
chain crops  (e.g., corn, wheat), up to 2.0  kg/ha (1.8  Ibs/acre)
of  cadmium  can   be  applied  annually.    In  all  cases,  the
soil/sludge pH must be adjusted to 6.5 or greater at the time of
sludge application (EPA, 40 CFR 257, 1979) .

     When sludge  is  applied to gardens  and  agricultural lands,
certain  crops  such  as  grains,  forage grasses, and vegetables
uptake cadmium.  The amount of cadmium uptaken by these crops is
a function  of  four processes which include  availability of the-
element  in   the  soil,  movement of  the  element  to the  root,
absorption of the  element  by the  root system,  and translocation
of  the  element  into  the  plant.   The  most   important  factor
limiting element  uptake is  the  soil   solution  concentration  of
micronutrients.  Studies have shown that the  amount of cadmium
applied annually influences the cadmium concentrations in plants
more than does the total cumulative amounts  of cadmium applied.
Cadmium  that  has  been previously  applied  is  less available  to
plants than  is  recently applied cadmium.  However,  when annual
cadmium  applications cease,  the  cadmium  stored  in   the  soil
becomes available to crops  (Pahren et al. 1979).  In contrast to
these ideas, Chaney  (1973)' suggests that it is not  the cadmium
concentrations  in  the  soil  that  determine  cadmium uptake  by
plants.  As  long  as  the  ratio  of zinc  to cadmium is 100  or
greater,  food  plants will  not  uptake and  accumulate  hazardous
concentration levels of cadmium (EPA 1976b).

     Fish,   such  as  salmonids and  certain  invertebrates,  have
been found to be sensitive to low levels of cadmium.   If exposed
to  high  enough  concentrations  edible  marine  organisms  also
concentrate  cadmium  and can become hazardous  to the  ultimate
consumer (EPA 1976b).
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Chromium

     Chromium occurs most predominately in nature as chrome iron
ore  (Venugopal  and  Luckey  1978) .   There  are  two  biologically
significant valence states in which chromium occurs as trivalent
and hexavalent.   The normal human adult body contains about 6 rag
of  chromium.   No particular  tissue retains  high concentration
levels.  Chromium can  accumulate  in the lungs with age, but the
levels are usually harmless.

     Chromium is an essential component of the glucose tolerance
factor.  Because of  its low molecular  weight,  chromium can act
as a cofactor for insulin activity and help to alleviate some of
the  symptoms of  diabetes.   Chromium  is   also  important  with
carbohydrate  and  lipid metabolism,  and membrane transportation
of cell metabolites  (Venugopal and Luckey 1978).

     Chromium toxicity is  attributed  to  the  hexavalent  state
(Hammond  and Beliles  1980).   The  principal  toxic effects  of
chromium in  humans  results  from exposure to  chromium compounds
in  industries and ingestion  of  potassium  dichromate.   Workers
who  are  exposed  to  chromium  compounds develop  skin  problems,
lesions  on the  nasal  mucosa,  and  inflammation  of the  larynx
(Browning  1961).   Ingestion  of  potassium  dichromate  causes
gastrointestinal  ulceration  and  affects   the  central  nervous
system (Venugopal and Luckey 1978).

     Nationwide,  chromium has been found  in  sludge at  levels
ranging  from 10-99,000  mg/kg dry  weight   with a  median  value
around 500 mg/kg (Chaney 1980).  From May 1981 to May 1982, West
Point's digested, dewatered sludge had a mean value of 390 mg/kg
of chromium and Renton's  raw,  waste  activated  sludge  had  a mean
value  of  287 mg/kg of  chromium  (Metro  1983a).   The  chromium
found  in  sludge  comes  from   a  variety of industrial  sources
including  electroplaters  (Cochran  pers.   comm.).    The  human
health hazards  associated with sludge  containing chromium have
not  been  well  studied.   It  is   known,   however,   that  all
hexavalent chromium is reduced to the less  toxic trivalent state
either during sludge  digestion  (Pahren  et al  1979)   or  after
sludge is applied to the soil  (Chaney 1973).

     Trivalent  chromium in the  soil  is  an  insoluble  element,
(i.e., an  element that  is  tightly  bonded  to  soil particles).
Because  of chromium's  insoluble  nature, plants  are unable  to
accumulate large quantities,  even  in the presence  of high soil
levels (Pahren  et  al.  1979).   Thus, the likelihood of  chromium
accumulating in the food chain is low.

     Trivalent  chromium  is  an  essential   component  of  animal
diets.  It aids  in the metabolism of glucose and lipids  (Hammond
and Beliles 1980).
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Copper

     Copper is  widely distributed in  nature as  a  native metal
and in sulfide  ores,  malachite,  cuprite,  and chalcopyrite.  The
normal human adult body  contains  about 100 mg of copper.  About
one-third of  this  is stored  in  muscle tissues.   Other storage
areas include the brain and the liver.

     Copper  is  an   essential component   of  iron  utilization,
connective  tissue  formation,  pigmentation and enzymes  used in
energy production.   The  human body has an effective hemostatic
mechanism  which regulates  the  absorption  of copper.   Copper
deficiencies in humans  result in anemia, abnormal  bones,  poor
growth, defective connective tissue,  cardiovascular failure, and
death  (Venugopal and Luckey 1978).

     Copper poisoning often  occurs  in  humans following  over-
exposure  to agricultural  insecticides  or  other toxic  copper
salts and inhalation of metal dust (Venugopal and Luckey 1978).

     The level  of copper in sludge ranges  from  84-17,000  mg/kg
dry weight with a median value of 800 mg/kg (Chaney 1980).   From
May 1981  to May 1982, West Point's digested, dewatered sludge
had a  mean value  of 1,160 mg/kg of  copper and  Renton' s  raw,
waste  activated  sludge had  a  mean value of  997 mg/kg  of copper
(Metro 1983a).   In  the  Seattle area,  the  main source  of copper
in  sludge  is  primarily  from  the  water  supply system   (Cochran
pers.   comm.).   The  human health  hazards  associated  with sludge
containing  copper  are  slight  because  of  the  human  body's
hemostatic mechanism  (Hammond and Beliles 1980).

     Copper can cause  phytotoxicity  in  plants  if applied  in
excess amounts  to  croplands.   Because copper  is  so phytotoxic,
severe field  reduction  occurs in most plants before  copper is
appreciably increased in edible plant tissue.  Generally, plants
show phytotoxicity  at about  25-40 mg/kg  dry weight.   The  food
chain is basically protected from copper accumulation because of
these two factors (Chaney in Bitton et al. 1980).

     Copper  toxicity to  domestic  animals  and   ruminants  from
sludge-fertilized  crops   appears   extremely  unlikely.   Studies
have   shown  that   after '  direct  consumption   df   sludge  or
sludge-contaminated forages or sludge from the soil surface, the
interaction of  other  dietary constituents  with  copper is  so
pronounced that copper concentrations in the liver were depleted
rather than increased to toxic levels (Chaney in Bitton et al.
1980).   The likely  consequence   of  applying  sludge  containing
large  quantities  of  copper  is a  reduction   in  molybdenum
available   for   animal  dietary   intake.    This   is  especially
possible  in areas  already  low  in  molybdenum   (Chaney  1980).
According to EPA (1977)  it  has been  demonstrated  that the total
cumulative  loading  of 125-500  kg/ha  (depending  on  the cation
exchange capacity)  of copper to agricultural land has not led to
observed problems.
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Lead

     Lead is a metal which  is  found  in galena,  an abundant lead
ore.  The normal human adult body contains between 100-400 mg of
lead, depending  upon  body  weight  (Browning  1961).   Almost  96
percent   of  the  body's  total  lead  content  is  stored  in  the
bones,  with  the  remaining  4   percent  being  stored  in  soft
tissues such as liver,  kidneys, and brain.   The concentration of
lead in humans increases  with age (Venugopal and Luckey 1978).

     The  toxicity of  lead   is  related more  to  the  levels  of
diffusible lead and to the  lead  content of soft tissues than to
the  total content  of lead  in  the  body-   Lead poisoning  is
cumulative and acute toxic symptoms include lassitude, vomiting,
loss of appetite, uncoordinated body movements,  convulsions, and
eventually death.  Chronic  lead  poisoning  symptoms include loss
of  appetite,  vomiting,  renal malfunction,  hyperactivity, liver
cirrhosis,   brain   damage,    and   general   intellectual   and
psychological  impairment.    Lead  poisoning  can  result  from  a
variety  of  sources:   ingestion  of  lead  from  lead-glazed  clay
cooking utensils,  paints,  newsprint,  waterfowl has  been  killed
by  lead-shot,  inhalation  of lead pigment  in  paints,  lead fumes
from  gasoline,  and lead   smelting  operations   (Venugopal  and
Luckey 1978).

     Nationwide  the  level  of  lead   in   sludge  ranges  from
13-26,000 mg/kg dry weight  with  a median value  around 500 mg/kg
(Chaney  1980).   From May  1981  to  May  1982,   West  Point's
digested, dewatered sludge had a mean value of 720 mg/kg of lead
and Renton's raw, waste activated sludge had a mean value of 280
mg/kg of  lead  (Metro  1983a) .   The  lead  found  in  Metro  sludge
comes primarily  from industries, the  water supply  system,  and
urban runoff.   Urban  runoff, which  accounts  for  10  percent  of
the  lead  in  sludge,   comes  mainly  from  automobile  exhaust
(Cochran pers. conun.) .   The human health hazards associated with
sludge  containing  lead  vary  with  the  concentration  levels.
Sludge having  over 1,000  mg/kg of  lead  may pose a  threat  to
humans,  especially children  if  the  lead-contaminated soil  is
ingested directly  (Chaney 1980) .

     Lead is generally not  toxic to plants.   The  amount of lead
taken up  from the  soil  depends upon soil pH,  cation-exchange
capacity  and  availability of  phosphorus.   Generally,  as these
factors  increase,  the amount  of lead  taken up  from  the  soil
decreases  (EPA  1976a) .   Lead is considered to be  an insoluble
element in the  soil  (Chaney in Bitton et  al.  1980) .   Insoluble
elements  are  generally held strongly  by  the clay  fraction  and
are  not  readily available  for  plant uptake  and  translocation.
In general, any lead taken up by plants accumulates in the roots
and  not  the  fruits and  seeds (EPA  1976a) .   The  food  chain  is
basically  protected from  lead  accumulation  by  the  insoluble
nature of lead and the adsorption to clay  soil particles.
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     Lead  toxicity  in  animals  occurs  when the  dietary intake
approaches 30 rag/kg.  Animals  foraging on crops grown on sludge
fertilized  croplands  are  generally  protected  from  absorbing
excess  lead.   However,  when  animals  directly  consume  high
lead-contaminated soil, toxicity may result  (Chaney in Bitton et
al.   1980) .    According  to  the   EPA   (1977) ,   it   has  been
demonstrated  that  total  cumulative   loading  of  500   (cation
exchange  capacity  of 0-5 meq/100  g)   to  2,000  (cation exchange
capacity  of greater  than  15  meq/100 g) .   Kg/ha  of  lead  to
agricultural land has not led to observed problems.


Mercury

     Mercury occurs  chiefly in the  form of cinnabar  ore.   The
normal human adult body contains about  13 mg of mercury.  Almost
70 percent of the body's  total  mercury content is stored in fat
and muscle  tissue.   Trace amounts  are also stored in  hair and
nails (Venugopal and Luckey 1978).

     Mercury is toxic  in  all forms.   Acute  symptoms  of mercury
poisoning vary, depending upon what form  of mercury  was either
ingested  or  inhaled.   For  example,   inhalation  of  elemental
mercury vapor  causes  damage to the  nervous  system and possibly
death.  Inorganic mercury intoxication causes  nausea,  abdominal
pain, stomatitis, gingivitis,  and  other more serious conditions
(Venugopal and Luckey 1978) .

     Mercury   toxicity    is   a   world-wide  problem.    Mercury
poisoning can result  from exposure  to  agricultural insecticides
and fungicides containing mercury, eating fungicide-treated seed
grain or meat from animals fed such grain, seafood from mercury-
contaminated waters,  and  from  inhalation of mercury  vapors  in
scientific and medical laboratories  (Venugopal and Luckey 1978).

     Nationwide  the  level  of  mercury  in  sludge ranges  from
0.6-56  mg/kg dry  weight  with  a median  value  around  6  mg/kg
(Chaney 1980).  From  May  1981 to May  1982,  digested,  dewatered
sludge from West Point had a mean value of 6.2 mg/kg of mercury
while raw, waste activated sludge from Renton's had a mean value
of 3.1 mg/kg of mercury (Metro 1983a).   The source of mercury in
Metro sludge is unknown (Cochran pers.  comm.).

     Mercury  is  generally not  phytotoxic  to  plants  because
mercury in the soil is an insoluble element  (Chaney in Bitton et
al. 1980) .   Even  with the increased  amounts of  mercury  in the
soil  from sludge applications,  plants  have not  increased the
amount of mercury uptaken to a point of toxicity  (Chaney 1980) .
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Molybdenum

     Molybdenum occurs  naturally  as molybdenite  sulfide  and as
lead and iron molybdates.   The  normal  human adult body contains
approximately 9.3 mg of molybdenum.  Molybdenum is stored in the
body in the skeleton and the liver.

     Molybdenum has low toxicity for humans and is generally not
considered a serious hazard (Venugopal and Luckey 1978) .

     Nationwide the  level of molybdenum  in sludge  ranges  from
1.2-40  mg/kg  dry  weight  with  a  median  value  around  10  mg/kg
(Chaney 1980).  Neither West  Point's  digested,  dewatered sludge
nor  Renton's  raw,  waste  activated   sludge   was  tested  for
molybdenum from May 1981 to May 1982 (Metro 1983a).

     The  amounts  of   molybdenum   uptaken  by   plants  depends
primarily  on  the  soil  pH.    In  highly  acid  soils,  little
molybdenum  is  available  for  plant uptake (Lindsay  1973).   In
calcareous  soils,  plant  uptake  is  high  because  molybdenum
sorption  is  weak  (Chaney  in  Bitton et  al. 1980) .   Plants  can
tolerate high  levels of  molybdenum without phytotoxic  effects
(Chaney 1980).  Once molybdenum has been  taken  up by plants, it
can easily be transported to the edible portions of plants.

     Ruminant  animals   are  susceptible to molybdenum  toxicity
because molybdenum can  react  to bind upon dietary copper in the
liver   (Chaney  in  Bitton  et  al.  1980)  .   Only  substantially
molybdenum-polluted  sludges cause  toxicity in  ruminant animals.
because generally sludges  also contain  copper which interacts
with the molybdenum  (Chaney in Bitton et al. 1980).


Nickel

     Nickel  is widely  distributed  in nature  as  deposits  of
sulphide ore which contain pentlandite, chalcopyrite, pyrrhotite
and in  combination with arsenic in  kupfernickel, nickleglance,
and nickelblende  (Browning  1961) .   The normal  human  adult  body
contains about  10 mg of  nickel,  with approximately  18  percent
deposited  within  the  skin.   The  remainder   is  distributed
throughout the body  (Venugopal and Luckey  1978).

     Humans  are   exposed  to  nickel  compounds  from  the  soil,
water,  atmosphere,  and  plants.    The toxicity  of  nickel  is
considerably less  serious  than  is  its  possible  carcinogenicity-
Acute  toxicity  will cause  severe  gastroenteritis and  chronic
toxicity results  in degenerative  changes in the  heart  muscle,
brain, lung, liver, and kidney  (Venugopal  and Luckey 1978).

     In the United States the  level of nickel  in sludge ranges
from   2-5,320  mg/kg  dry  weight  with   a  median   value   of
approximately  500  mg/kg  (Chaney  1980) .    From  May 1981 to  May
1982 digested,  dewatered  sludge from  the West Point treatment
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plant had  a  mean value of 155 mg/kg  of  nickel while raw, waste
activated  sludge  from  Renton's had a mean value  of 91 mg/kg of
nickel  (Metro  1983a).   Nickel  found  in  Metro  sludge  comes
primarily  from electroplating  industries (Cochran pers. comm.).
The  human  health  hazards  associated  with   sludge  containing
nickel are not  considered to be  of  significant concern because
nickel is  readily excreted from the  body and of low toxicity to
humans (Lucas et al. 1978).

     Nickel  can cause  phytotoxicity  in plants  if  applied  in
excess  to  croplands.    Nickel  phytotoxicity   appears  in  most
plants when nickel levels  reach about 50-100 mg/kg dry weight in
the  leaves.   This  is  true, for  grasses,   legumes,   and  leafy
vegetables.  Low soil pH enhances phytotoxicity in plants (Lucas
et al. 1978).

     Nickel  toxicity   in  ruminants and  monogastric  animals  is
generally not a problem.  When nickel was added to cattle diets,
no toxicity  was  observed  at 250 mg/kg.   Grains and garden crops
also  do  not  accumulate high  levels  of  nickel which  could  be
toxic to  monogastric   animals  (Chaney 1980).    According  to  EPA
(1977),  it has  been demonstrated that total  cumulative loading
of 50-100  kg/ha  (depending on  soil cation exchange capacity)  of
nickel to agricultural  land has not led to observed problems.


Selenium

     Selenium occurs  naturally  as metallic  selenides in  very
small quantities.   The average human adult body  contains about
13  mg of  selenium,  with  approximately  40  percent  stored  in
muscle tissue.

     Selenium intoxication can  occur  in humans  from consuming
cereals,  grains, and vegetables  grown on soils containing up to
5  mg/kg  selenium  and  meat  of  animals  reared in  seleniferous
areas.  Selenium toxicity or  selenosis,  can  be  caused by  both
organic  and  inorganic  forms.    Symptoms   of  acute  selenium
poisoning  include  nervousness, fever, vomiting,  and decreasing
blood   pressure.    Chronic   toxicity   produces   depression,
gastrointestinal disturbances,  kidney, liver  and  spleen damage,
hemolytic  anemia,  and  loss of  nails and  hair  (Venugopal  and
Luckey 1978).

     Nationwide,  selenium has  been  found in  sludge  at  levels
ranging from 1.7-17 mg/kg  with a median value of  5  mg/kg  dry
weight  (Chaney  in Bitton  et al.  1980).   Neither  West Point's
digested,   dewatered sludge  nor  Renton's  raw, waste  activated
sludge was tested for  selenium  from May  1981  to May 1982  (Metro
1983a).

     No serious  human  health hazards  are associated with sludge
containing selenium except  in  areas where  crops are  grown  on
soils that have naturally high concentrations of selenium (Lucas
et al. 1978).
                              199

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     Selenium is readily absorbed from the soil by plants.  Once
absorbed it is  translocated  to  edible portions of plant tissue.
Plants generally can accumulate toxic levels of selenium without
showing signs of  phytotoxicity.   In  areas  where  naturally high
concentration levels of selenium occur  in  soils,  or in areas of
high  soil  pH,  the  level  of plant  uptake  is  great.   In such
areas,  the  food  chain  is  generally  not  protected;  however,
sludge concentrations of selenium are quite  low and consequently
the amount absorbed by plants in the  food chain is small.

     Ingestion of sludge containing  5 mg/kg of selenium has not
adversely  affected  grazing ruminants  (Chaney  in Bitton  et al.
1980) .
Silver

     Silver  occurs  in  nature  as  free  metal  in  ores  such  as
argentite and horn silver.  The normal human adult body contains
about  1  mg  of silver.  The  total  amount of silver  in the body
varies  with the  length  of  time  an  individual  is exposed  to
silver compounds (Venugopal and Luckey 1978) .

     Silver  toxicity  in humans can occur  after free  silver  is
either  inhaled  or  ingested.   Acute toxicity  symptoms  following
the ingestion of silver nitrate include  severe gastroenteritis,
diarrhea, decrease in blood pressure and decrease in respiration
rate,  and eventually death.   The central nervous  system is also
affected by  acute toxicity.   Chronic  toxicity  symptoms from low
levels  of  silver  salts  are  fatty  degeneration  of  liver  and
kidneys,  changes  in  blood  cells  and   argyria  (Venugopal  and
Luckey 1978).

     Neither West Point's digested, dewatered sludge nor Renton's
raw, waste activated sludge was tested for  silver  from May 1981
to May  1982  (Metro  1983a).   Any silver  found  in  Metro  sludge is
likely to come  from industries  such as  photo  finishing  (Cochran
pers. comm.).

     Silver  is generally  not  phytotoxic  to  plants  because it is
an  insoluble element  in  the  soil.   Insoluble elements  are  not
uptaken and  translocated by plants in  large quantities, thus the
chances of  silver accumulating in  the food chain  are  quite low
(Chaney _in Bitton et al. 1980) .


Zinc

     Zinc occurs in nature in a wide  variety of  forms:   as the
sulfide blend or sphalerite  as  silicate, calamine,  willemite or
zinc spar,  and  as  the  oxide  zincite.   The average  human adult
body contains  about 2,300 mg of zinc,  with  65 percent  in  the
muscle, 20 percent in the bone, 6 percent in plasma, 2.8 percent
in the erythrocytes, and 3 percent in  the liver.
                              200

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     Zinc  and  its  salts  are   relatively  nontoxic  to  humans
because of  an efficient zinc hemostatic  mechanism in the body.
If taken in  large  doses,  however, zinc  soluble  salts can cause
vomiting  and  diarrhea.   Industrial  inhalation  of  zinc  oxide
fumes can  cause metal  fume fever, and  zinc chloride  fumes in
heavy concentrations have been found to be highly toxic and even
lethal in some cases (Venugopal and Luckey 1978).

     Nationwide, zinc has been found in sludge at levels ranging
from  101-149,000  mg/kg dry weight with  a  median  value  around
1,700 mg/kg  (Chaney  1980).  From May  1981  to May  1982  West
Point's digested,  dewatered sludge  had  a  mean  value  of 1,780
mg/kg while  Renton's  raw,  waste  activated  sludge had.  a  mean
value of  644  mg/kg (Metro '1983a) .   The zinc   found  in  sludge
comes primarily from  the  water  supply  system  (Cochran  pers.
comm.).    The  human  health  hazards   associated  with  sludge
containing   zinc   are   slight  because   of   the  human  body's
hemostatic  mechanism.    Because   many   individuals  consume  low
amounts of  zinc, additional amounts  of zinc taken into the body
from  eating  plants grown  on  sludge  amended   soils  might  be
beneficial  (Chaney in Bitton et al. 1980).

     Zinc  can  cause  phytotoxicity   in   plants  if applied  to
croplands   in   excess.    In   general,   most   plants   show
phytotoxicity  at  about 500  mg/kg dry weight;  leafy  vegetables
such as lettuce and chard do not show phytotoxicty  in acid soils
until  foliar  zinc  levels  are   about  1,500  mg/kg dry  weight.
Crops grown  on sludge amended soils  are seldom as high  as  500
mg/kg  for   zinc.    According   to  EPA   (1977) ,   it   has  been
demonstrated  that  total  cumulative  loading of  250-1,000  kg/ha
(depending  on  soil  cation  exchange  capacity)   of  zinc   to
agricultural land has not led to observed problems.

     Zinc  toxicity  to  domestic  animals  and  ruminants  from
sludge-fertilized  crops  appears  to   result  from  zinc-induced
copper  deficiency.   Toxicity  in  animals  occurs   at  300-1,000
mg/kg in diet  (Chaney in Bitton et al. 1980).


                            Bacteria


Salmonellae

     Salmonellae   bacteria   are  gram-negative,   facultative,
anaerobic rods  ranging in  size  from  0.5-3  urn.  Members  of  the
Salmonellae  genus  are  responsible for a wide variety  of human
and animal diseases and are often associated with food and water
contamination.  The most common form of Salmonellae infection in
humans  produces   gastroenteritis.    Gastroenteritis   symptoms
include nausea,  vomiting,  abdominal  pain,   and  mild  to  severe
diarrhea.   The  most severe  disease manifestation  of salmonella
is typhoid fever,  caused by S.  Typhi (Slack and  Snyder 1978).
                              201

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     Salmonellae  bacteria  are  the  most  frequently  occurring
species of enteric pathogens in sewage (Akin et al. in Sagik and
Sorber  eds.  1978).   From  May  1981  to  May  198T~ digested,
dewatered sludge  from  Metro's  West Point treatment plant had a
mean  value  of   95  organisms  per  100  grams   (wet  weight)  of
salmonellae  while Renton's  raw,  waste  activated  sludge  had a
mean  value  of   60  organisms  per  100  grams   (wet  weight)  of
salmonellae  (Metro 1983a).

     Salmonellae bacteria in sludge applied to land after sewage
treatment  persists  anywhere  from  a  few  days  to  7  weeks,
depending  upon  initial  concentration  levels  and  environmental
conditions.  Human  health problems associated  with salmonellae
in   sludge   involve    potential    surface    and   groundwater
contamination and possible  cross-infection  between  animal and
man  (Metro 1983c).
Shigallae

     Shigellae   bacteria    are    gram-negative,    facultative,
anaerobic,  nonspore  forming rods.   Shigellae do not  ferment
lactose  or produce  hydrogen sulfide  (Slack  and  Snyder 1978) .
Shigellae  infection in humans can occur from digesting as few as
10-100  S.  dysenteriae  cells.   The  enteric  diseases  caused by
shigellae   bacteria  are   collectively   called   dysentery  or
shigellosis  and  are  characterized  by  fever,  diarrhea,  and
cramping.

     Shigellae bacteria are  found in sewage at levels lower than
salmonellae.  From  May  1981 to May  1982  West  Point's digested,
dewatered  sludge  had a  mean value  of  less  than  0.3  MPN/100  g
while Renton's raw,  waste  activated sludge had a  mean value of
less than  0.3 MPN/100 g  (Metro 1983a).  Neither the human health
hazards associated with sludge containing shigellae bacteria nor
the persistence of shigellae in sludge have" been well studied.


Yersinia enterocoliticia

     Yersinia   enterocoliticia   bacteria  are   gram-negative,
nonspore forming facultative anaerobic rods ranging in size from
0.5-2 um.   The  bacteria are motile  at  22-25°C and nonmotile at
35-378°C.   Yersinia  enterocoliticia   bacteria  are  found  in
domestic and wildanimalsandaretransmitted to humans through
contaminated food and water.   The most  common form of infection
in humans  is gastroenteritis.  The bacteria can also cause acute
mesenteric lymphadenitis, septicemia, and acute terminal ileitis
(Slack and Snyder 1978).

     From  May 1981 to May 1982, West Poyit's digested, dewatered
sludge  has a mean  value of 0.15 x  10   MPN/100   g  of Yersinia
enterocoliticia and  Rentpn's raw, waste  activated sludge  has  a
mean value of  0.36 x 10  MPN/100 g of Yersinia enterocoliticia
                              202

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(Metro 1983a).  Yersinia  enterocoliticia  bacteria was suggested
by Turnberg to be more resistant to disinfection by chlorination
than other enteric bacteria  in  sewage (Turnberg 1980).  Neither
the length of time Yersinia enterocoliticia bacteria persists in
sludge nor the human health hazards associated with the bacteria
in sludge have been well studied.


Mycobacteria

     The  genus  mycobacteria  are  generally gram-positive  rods
ranging   in   size  from   2-4   urn.   Mycobacteria   are   widely
distributed throughout the environment and in humans and animals
(Slack and Snyder 1978).   There are approximately 12 species of
mycobacteria  that cause   disease  in  humans.    The  best  known
mycobacteria, M.  tuberculosis  causes tuberculosis.    M.  bovis,
the tuberculosis  agent  in cattle,  can be  transmitted  to humans
through close contact with infected animals.  Other mycobacteria
can cause skin  lesions  and ulcers and  cervical lymphadenitis
(Metro 1983c).

     Mycobacteria levels  were  monitored  at  the West  Point  and
Renton's  Treatment Plants  from June  1981  to August  1981 (Metro
unpublished data).  The mean mycobacteriaj- level in West Point's
digested, dewatered  sludge was  2.0 x 10   colony-forming  units
(CFU)  per 100 grams  (cfu/100  g).  At Renton the  mean  level  was
3.0 x  10  cfu/100 g.  The  persistence of  mycobacteria  in sludge
varies from a few weeks to 1 year.  Generally,  mycobacteria  are
considered  to  be  environmentally  hardy  and  refractory   to
chlorination and liming (Metro  1983c; Sagik  et  al.  iri  Bitton et
al.   1980).    Human   health   hazards   associated  with   land
application of sludge containing mycobacteria have not been well
studied.

     Studies  of mycobacteria  survival in  composted  sludge  have
shown nearly  complete die-off within  14  days under temperatures
of  65°C   or   higher.   Mycobacteria  survival was found  to  be
considerably  longer  when  low  ambient temperatures  (lower  than
0°C)   affected compost temperatures,  particularly on  the  outer
portions of windrow compost piles  (Burge et al.  1978).


Fecal Coliforms

     Fecal coliforms  are  a  subgroup of  total  coliforms.   The
fecal coliforms are thermotolerant and  can ferment lactose  with
gas production  at 44.5°C.  Generally,   fecal  coliforms are  of
fecal  origin.  Escherichria  coli  is one  of  the most  common
species of fecal  coliforms found  in  sewage.   Escherichria  coli
in humans can cause  diseases  in  infants  and  adults that  may
range  from mild  diarrhea  to cholera-like  illness  (Sagik et  al.
in Bitton et al.  1980) .
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     From May 1981  to  May 1982 fecal coliforms  in West Point's
digested, dewatered sludge had a mean value of 0.20 MPN/100 g wt
and in Renton's raw, waste activated  sludge  had  a mean value of
0.24 MPN/100 g wt (Metro 1983a).

     The viability of E. coli  in  sludge  applied  to land depends
upon many  environmental  factors.   E_. coli  have been  found in
high concentration  levels  2  months after  sludge application to
soils.    Concentrations  of  E.   coli  tend  to be  higher  in  the
winter season  than  in  the  summer season  (Metro 1983c) .   Fecal
coliforms   from  sludge-amended   land   have   been   found   in
groundwater  sampling   wells   at   100  cm  deep   at   rates   of
approximately 200 cells per  100 ml  MPN  and less.  Surface water
runoff from  sludge-amended  land has also  contained high levels
(5.5 x  10   cells/ml)  of fecal coliforms.  Forty-two  days after
application,  the  surface  water   runoff  still  contained   60
cells/ml of fecal coliforms (Metro 1983c).

     Studies  of  fecal  coliform  survival  in   forced  aeration
static pile  composted  sludge  have  shown that after  an initial
increase   in   numbers,   coliform   bacteria   were  reduced   to
undetectable levels by the tenth day of composting  (Burge et  al.
1978; EPA 1978a).
Total Coliforms

     Total coliforms are a group of gram-negative, nonperforming
bacilli that ferment lactose with  gas  formation within 48 hours
at  85°C.   Bacteria  in   this   group   are  widely  distributed
throughout  the  environment and  in humans  and  animals.   Total
coliform  counts  are  used  as  a  standard  for  determining  the
safety of drinking water and surface water for human use.

     From May 1981 to May  1982 West  Point's digested,  dewatered
sludge  had a  mean  value  of  0.23  x   10   MPN/100  g  of  total
coliforms  and  Renton's  raw, waste  activated sludge had  a mean
value  of  0.30  x   10   MPN/100  g  of  total  coliforms   (Metro
1983a).   Neither  the  persistence  nor  human  health  hazards
associated with  total  coliforms  in sludge  applied  to  land have
been well studied.

     Reductions  in  numbers of  total  coliforms  in  composted
sludge have been shown to parallel  reductions in fecal coliforms
and fecal streptococci numbers  (Cooper and Golueke 1979) .


Fecal Streptococci

     Streptococci  are   a  group  of  spherical,   nonmotile  (with
exceptions), nonsporing bacteria which  average  1 pm in diameter
(Burnett and Schuster 1973).  The bacteria are gram-positive and
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cocci  occur  in  pairs  and  sometimes  chains.   Streptococci are
found  in  intestinal tracts  of  humans  and  warm-blooded animals
(Slack and Snyder  1978).   Fecal  streptococci  are not generally
associated with  any one disease.   They are, however, used as an
indicator of fecal pollution  (Hunger pers.  comm.).

     From  May  1981  to  May  1982  fecal  streptococci  in  West
Point's digested,  dewatered sludge had  a mean value  of 0.33  x
10   MPN/100  g wt  and  in  Renton's raw,  waste  activated sludge
had  a  mean  value  of  0.76 x  10   MPN/100  g wt  (Metro 1983a) .
Fecal  streptococci  in  an  anaerobic  digested  sludge  applied to
land has survived in the soil  for as  long as 7 months  (Sagik et
al.  in Bitton  et  al.   1980)..   The  incidence  of  public- health
hazards associated  with land  application  of  sludge containing
fecal   streptococci   needs   further   investigation,    although
considerable  study has  been  made  of  the survival   of  fecal
streptococci in  composted  sludge  (EPA 1978a; Cooper and Golueke
1979) .
                            Parasites
Ascaris lumbricoides
     Ascaris  lumbricoides,  commonly referred  to  as roundworms,
are  one  of the  largest intestinal  nematodes found  in humans.
The  adult  roundworm  lives  in  the  small   intestine  and  the
intermediate host for the eggs  is the  soil.   The  length of time
that the eggs remain in the soil varies, depending upon the worm
species and environmental condition, but it is usually a minimum
of  2-4 weeks.   During this time,  the  eggs undergo  a period of
development.  These  eggs  are  very resistant  to a  wide  range of
chemical and  physical  conditions and  often  remain infective in
the  soil  for  many years  (Little  in Bitton et al.  1980).   When
ingested by humans,  either  through  contaminated  food or water,
the  roundworms  can  cause  lesions  on  the   lungs,  hemorrhage,
fibrosis,  and secondary  bacterial  infections.  Acute  symptoms
include  intestinal  obstruction  and  nutritional  deficiencies
(Brooks 1963) .

     From May 1981 to May 1982, West Point's digested, dewatered
sludge  contained  three  positive   identifications  of  Ascaris
lumbricoides out  of  16  samples.   Renton's raw, waste activated
sludge did not  have any  positive  identifications  of  Ascaris
lumbricoides out of  10 samples  (Metro  1983a).  There has been a
considerable amount  of research done on Ascaris  lumbricoides in
sewage  and  sludge   applied  to  land.   In  general,  anaerobic
digestion appears to be ineffective  in destroying parasites, and
the  dewatering  process  tends  only to  concentrate  the  parasite
eggs  (Metro  1983c).   Dewatered  sludge  in  drying  beds  has
characteristics   similar  to    those   of  soil,    and   in   some
circumstances   may   provide   an   ideal   medium   for   Ascaris
lumbricoides eggs to develop  to the infective stage (Little in
Bitton et al.  1980) .
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Giardia lamblia

     Giardia  lamblia  is a  small  flagellate  protozoan  parasite
found in the  digestive  tract of humans.  The parasite  may live
harmlessly  in  the  digestive  system  or  be  associated  with
diseases  of  the   gastrointestinal   tract   and  gall  bladder.
Infection with  Giardia  lamblia is called giardiasis.   Symptoms
include  flatulence,  upp'er  abdominal  pain,   nervousness,  weight
loss, constipation, and diarrhea (Brooks 1963).  Giardia lamblia
is readily transmitted  to humans by  contaminated food and drink
and  hand to  mouth  contact  (Beck  and  Davies  1981) .   Giardia
infections  are  often   associated   with drinking  water  from
contaminated mountain streams.

     From May 1981 to May 1982, West Point's digested, dewatered
sludge  contained  one positive  identification of giardia  in  16
samples  and  Renton's  raw,  waste activated  sludge  contained one
positive   identification   in   10   samples    (Metro   1983c).
Conflicting information  exists  on  the public  health  hazards  of
giardia  in  sewage.  Healy  and  Visvesuara  (1977)  reported that
very  little  was known  about  the  role  of  sewage sludge  in the
acquisition of giardiasis.   In 1978,  Fox and Fitzgerald observed
that   giardia  does   not   survive   anaerobic  digestion  and
consequently  appears  not  to  pose  health  problems  in  land
application  of  digested  sludge  (Metro  1983c).   It  should  be
noted that giardia cysts can survive normal  chlorination of city
water  (Beck and Davies  1981).   Whether  giardia can also survive
chlorination in sewage treatment needs further investigation.


                          Enteric  Viruses

     Enteric  viruses  is a  collective  term  that  encompasses
polio,  coxsackie B,  echo,  coxsackie A,  adeno,  and  reo  viruses.
All of these viruses are enteroviruses.   These viruses produce a
variety  of   symptoms  in  humans   including  gastroenteritis,
paralytic polio, respiratory  disease,  meningitis,  encephalitis,
congenital heart  abnormalities,  skin rash,  conjunctivitis,  and
infectious hepatitis.

     Enterovirus  concentrations  in   sewage   influent  can  vary
depending  upon  geographic   location,  climate,  and  nature  of
sewage.   Residential sewage  has  a  higher  virus  content than
industrial  sewage  or   combined  storm   and  sanitary   sewage.
Certain  enteroviruses  can  survive  anaerobic digestion  and are
transmitted  to  soils   and  water   during land   applications  of
sludge  (Metro 1983c).

     Studies  of  virus  survival in  forced aeration static pile
composting have shown destruction  of indicator viruses within 13
days  except  at  the outermost  edge  of  the  composted  material
(Burge et al. 1978).
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     West  Point's  digested,   dewatered   sludge  contains  eight
plaque-forming  units  per  100 gram  weight  (pfu/100  g  wet)  of
total viruses and Renton's  raw,  waste activated sludge contains
30 pfu/100 g wet of total viruses (Metro 1983a).


                        Organic Toxicants


Aldrin/Dieldrin

     Aldrin  and dieldrin  are manmade cyclodiene  insecticides.
These insecticides  have  been  used in the  past to  control pests
on 46 agricultural  crops,  for treatment of  soil  around fruits,
nuts, grains,  and  vegetables  and for moth proofing  of woolen
textiles  and  carpets.   Both  of  these insecticides  are acutely
toxic  to most  forms  of  life  including  anthropods,  mollusks,
invertebrates,  amphibians,  reptiles,  fish,  birds,  and mammals.
Dieldrin,  which  is  produced  when   aldrin  is   metabolically
converted,  is  extremely persistent  in  the  environment (Sittig
ed.  1980) .   The approximate half-life of  aldrin in  the soil is
1-4  years and  dieldrin  is 1-7  years (Dacre  in  Bitton et  al.
1980).    Dieldrin,   because  of its  fat  solubility,  can  easily
accumulate in the food chain.

     Aldrin and dieldrin have  persisted  in the environment and,
in   humans,   cause  irritability,   tremor,   and   tonic-clonic
convulsions; the central nervous system is the principal site of
action.   The insecticides  also  have  a  potential  carcinogenic.
effect (U. S. HEW 1978a and b).

     Both of  these  insecticides have been banned by  EPA  since
1974.   Certain  restricted  uses  of  aldrin  and  dieldrin  are,
however, currently permitted  (Frandsen pers. comm.).

     Sludge monitored at  the  West Point  and Renton's  treatment
plants from May 1981 to May 1982  did  not contain  any detectable
amounts  of  aldrin  or  dieldrin (Metro 1983a).   Specific sources
of aldrin and dieldrin in sewage  are  not known;  however, traces
of the insecticides in sewage may be from either incidental uses
or from residues in the environment (Cochran pers.- comm.).
PCBs

     Polychlorinated biphenyls,  commonly  referred  to  as  PCBs,
are the  chlorinate derivatives of  a class of  aromatic organic
compounds  called  biphenyls.   Since  their  introduction  into
commercial  use  in  1929,  PCBs have  become  widespread in  the
environment  through   vaporization   into  the   atmosphere  and
spilling  or  dumping  into  water  or  onto  land.    Commercial
products  containing  PCBs   are   used   in  the  manufacture  of
capacitors  and   transformers  and  other   closed  and  nonclosed
electrical  systems,  as well  as  insecticides.  Because  PCBs  do
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not easily disintegrate in the environment and accumulate in the
fatty tissue  and skin  of man  and other  mammals,  they  pose  a
serious threat  to  the environment and human  health (Sittig ed.
1980) .   The  approximate  half-life of PCBs  in  the soil  is  4 +
years.

     PCBs have caused serious toxic effects  in man and animals.
The  skin  and  liver  are  major  sites  of pathology  with  the
gastrointestinal tract  and nervous  system also  being targets.
In  addition,  studies  in  animals suggest  that  some  PCBs  are
carcinogenic  and  that they can  enhance  the  carcinogenicity of
other  chemicals.    Humans  are  exposed  to PCBs through  food,
water,  and air.

     PCBs  are  currently  not  produced  in the  United  States.
Manufacturing of PCBs was banned  in 1979  and  all processing and
distribution  for commercial uses  also ceased  in 1979.   The EPA
has specific regulations covering certain exemptions to this ban
and  for  the  disposal of  PCBs  (Sittig ed. 1980;  Frandsen pers.
comra.).

     From May 1981 to May 1982,  West Point's  digested,  dewatered
sludge  contained 1.6  mg/kg  of   PCBs  and Renton's raw,  waste
activated  sludge contained  0.5   mg/kg  of PCBs   (Metro  1983a).
PCBs in sludge come from both  point and nonpoint sources.  Point
sources include solvent plants and improper storage and handling
practices.  The  nonpoint  sources  are scattered  residues  in the
environment which cannot be isolated (Cochran pers. comm.).

     The  EPA  (1979c),   through   regulations   40  CFR  257,  has
established   that   any  solid  waste  (e.g.,   sewage  sludge)
containing concentrations  of  PCBs greater than 10 mg/kg  (dry
weight)  must be incorporated (by plowing  or injection)  below the
soil surface  if the  site is to  be  used  for producing  animal
feed.  At 1.6 mg/kg, Metro sludge is well below that level.


Chlordane

     Chlordane  is  a  manmade  cyclodiene  insecticide  which  has
been  used  extensively   over  the past  30  years-  for  termite
control,  as   an  insecticide  for  homes  and  gardens,  and as  a
control  for   soil  insects.   It   has  been detected at  various
concentration levels  in  ambient air,  drinking water, rainwater,
and  soils.   Also,  because  of  its fat  solubility, it  readily
accumulates  in   the  tissues  of  organisms  (Sittig ed.  1980).
Chlordane  is  quite  persistent  in  the environment  and   has  an
approximate  half-life of  2-4 years   (Dacre  iri  Bitton  et  al.
1980) .   This  insecticide  is highly toxic  to  aquatic organisms,
avian,  and mammalian species.
                              208

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     The  EPA banned  the  overall  use  of  chlordane  in  1978;
however,  certain  uses   are   still  permitted  such  as  termite
control and dipping of nonfood roots and tops for insect control
(Frandsen pers.  comm.).

     When  monitored  from  May 1981  to May  1982, neither  West
Point's  digested,   dewatered  sludge   nor  Renton's  raw,  waste
activated  sludge contained any detectable amounts  of  chlordane
(Metro 1983a).
DDT               ,               ,   ,

     DDT  is  a broad  spectrum insecticide  which has  been used
extensively throughout  the  United  States for  public  health and
agricultural programs.  This  insecticide  has several properties
that cause significant  environmental  and  human health problems.
DDT and its metabolites are toxicants with long-term persistence
in  soil  and  water;  it  is  widely dispersed  by  erosion,  runoff,
and  volatilization,  and   the low  water  solubility  and  high
lipophilicity of DDT  result  in concentrated  accumulation of DDT
in  the  fat of  wildlife and  humans.   DDT  is  acutely toxic  to
freshwater fish and invertebrates.

     Humans are  exposed to  DDT  primarily through  ingestion  of
contaminated food.  Air and water intake is generally negligible
except  in previously heavily sprayed agricultural  areas  where
large  amounts  of  residues  may  still  be  present.   DDT  is
suspected to be a human carcinogen (Sittig ed.  1980).

     The  EPA  banned  the  use   of  DDT  in  1972.   In  certain
emergency instances,  EPA may grant permission to use DDT again
for public health and vector control  (Frandsen pers. comm.).

     Neither  West   Point's   digested,  dewatered   sludge  nor
Renton's  raw,  waste  activated sludge contained  any  detectable
amount of DDT during the  sludge monitoring conducted from May
1981 to May 1982 (Metro 1983a).


Endrin

     Endrin  is  a  manmade  cyclodiene  pesticide.   Of  all  the
cyclodiene pesticides,  endrin is  the most  toxic,  but  is also
less persistent  in  the  environment  than DDT or  dieldrin  (U.  S.
HEW  1979).    This  pesticide has  been  predominately  used  to
prevent lepidopteron  larvae  from attacking  cotton  crops  in the
southeastern  and Mississippi delta   states.   Endrin  is  highly
toxic to  all  animals  regardless  of the route  of exposure.  The
primary toxic effect of acute exposure is on the central  nervous
system  (Sittig ed.  1980) .   the   approximate  half-life of endrin
in the soil is 4-8 years (Dacre  in Bitton et al.  1980) .
                              209

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     Humans are exposed to  endrin  through diet,  inhalation, and
dermal contact.  Agricultural workers,  home gardeners and other
people involved in  endrin manufacture and  distribution  are the
most  likely to  be  exposed to  endrin.   Quantitative data  on
endrin toxicity to humans are not available  (Sittig ed. 1980).

     The EPA banned the use of endrin in 1979.  However, certain
restricted  uses  of  endrin  are currently  permitted  (Frandsen
pers.  comm.).

     Neither West Point's digested, dewatered sludge or Renton's
raw, waste  activated sludge contain  any detectable  amounts of
endrin from May 1981 to May 1982 (Metro 1983a) .
Lindane

     Lindane  is  the common  name  for  the  insecticidally-active
hexachlorocyclohexane.   Hexachlorocylohexane is a broad spectrum
insecticide.  Lindane is used to control insects in a wide range
of treatments including  treatment of animals,  buildings, humans
for ectoparasites, clothes, water for mosquitoes, plants, seeds,
and soil.   The  insecticide is slow  to  disintegrate  in the soil
(10 percent degradation after 6 weeks) and is acutely toxic.

     Humans   are   exposed   to  lindane  through   ingestion  of
contaminated  food,  dermal  contact,  and inhalation.   Lindane is
suspected of being carcinogenic to humans (Sittig ed. 1980) .

     Lindane  used  in this country  is  currently  imported.   The
EPA has  not banned  the  use  of this pesticide; however,  it is
under review for regulatory action (Frandsen pers. comm.).

     Neither West Point's digested,  dewatered sludge or Renton's
raw, waste  activated sludge  contain any detectable  amounts of
lindane from May 1981 to May 1982  (Metro 1983a).


Methoxychlor

     Methoxychlor  is  a  synthetic  organo-chlorine  insecticide
that is similar  in structure to DDT.   This  insecticide  is used
on a wide range of insects that attack fruits,  vegetables, shade
trees,  home gardens, forage  crops,  and livestock.   Methoxychlor
is  generally  applied  directly to  crops  via  ground  or  aerial
spraying.    Methoxychlor  is  generally  considered a  relatively
safe pesticide with  a  low  order of  toxicity to humans and other
warm blooded animals.

     Human  exposure to  methoxychlor  is  through  inhalation or
ingestion of  contaminated  food.   Methoxychlor does  not  readily
accumulate in body tissues (U. S.  HEW 1978c).
                              210

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     This pesticide is currently  being  manufactured and used in
the United States.   The EPA has not taken any action to ban its
production and usage (Frandsen pers. comm.).

     During  sludge  monitoring  conducted  from May 1981  to May
1982,  neither  West  Point's  digested,  dewatered  sludge  nor
Renton's  raw,  waste  activated   sludge   contained  detectable
amounts of methoxychlor (Metro 1983a).


Toxaphene

     Toxaphene  is  a   broad   spectrum,  chlorinated  hydrocarbon
pesticide  that   is   primarily  used   to   control  insects  on
agricultural crops, especially cotton.   This  pesticide readily
accumulates  and  persists  in  living   organisms   and  sediments
(Sittig  ed.  1980).   The  approximate half-life of toxaphene in
the  soil  is  10  years   (Dacre  in Bitton  et  al.  1980) .   Toxaphene
is not  generally  found in  high concentration levels  in water.
However,  it  is highly toxic  to  many  aquatic invertebrate and
vertebrate species (Sittig ed. 1980).

     Humans are exposed to  toxaphene primarily through residues
in  air,  water,   and   food   (U.   S.  HEW  1979) .    Toxaphene  is
considered to be a likely human carcinogen and is known to cause
toxic reactions in the body  (Sittig ed.  1980).

     The  EPA  banned  the   production  of   toxaphene  and  its
subsequent use in November  1982.   All  existing  supplies may be
used  until  December 1986,  after which time only  certain uses.
will be exempt from the ban  (Frandsen pers.  comm).

     Both West Point's digested,  dewatered  sludge and Renton's
raw,  waste, activated  sludge contain no  detectable  amounts of
toxaphene (Metro 1983a).


2,4-D and 2,4,5-TP (Silvex)

     2,4-D and  2,4,5-TP   (Silvex)  are  chlorinated  phenoxy acid
herbicides that  are  used extensively  for weed  control.  These
herbicides are very potent even  at  low  concentrations  (American
Public Health Association et al. 1976).

     Humans are exposed to 2,4-D  and 2,4,5-TP through ingestion
of   contaminated   water,   and   food  and  direct   exposure.
Agricultural workers,  pilots, mechanics,  hand applicators, and
other  people  involved   in   2,4-D   and  2,4,5-TP   manufacture,
distribution and  application are  the most  likely  to  be exposed
to these pesticides.
                              211

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     The  EPA  banned  the  use  of  2,4,5-TP   (Silvex)  in  1979.
However,  certain  restricted  uses  of  2,4,5-TP  are  currently
permitted.  EPA  has not  taken any action on  the  usage  of 2,4-D
(Frandsen pers. comm.).

     Neither  West  Point's   digested,   dewatered   sludge   nor
Renton's  raw,  waste  activated  sludge  contain  any  detectable
amounts of 2,4-D or 2,4,5-TP (Metro 1983a).
                               212

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	Appendix B
 Properties of Forest Soils

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                           APPENDIX B


                   PROPERTIES OF FOREST SOILS


                          Introduction

     The addition of sludge to forest soils is likely to alter a
number of soil chemical properties and processes, including:

          o    pH
          o    Cation exchange capacity
          o    Mechanisms of cation movement
          o    Nitrogen cycling
          o    Heavy metal concentrations and mobility
          o    Organic toxins

£H

     Soil  pH is  an  important  soil  characteristic because  it
controls the  availability and movement  of plant  nutrients and
heavy metals  as well  as the  actions of  microorganisms.   Most
forest  soils  in western  Washington  have  a  pH between  4.5 anc"
6.0,  while the  pH  of digested,  dewatered  sludge from  local
treatment plants averages about 7.4.  This high  pH results from
ammonium  produced  metabolically   during   anaerobic  degradation
(Mayer,  1980).

     Following application of  sludge to forest  land,  the  pH of
the  sludge  begins  to  drop  due  to  acidic  throughfall  and
litterfall,  formation   of   organic  acids   and  nitrification
(conversion of  ammonium  to nitrate)  (Alexander,  1977) .   During
that time, the pH of the soil underlying the sludge may increase
slightly (Harris in Sopper and Kerr, 1979).

     The rate of pH change in both the sludge and soil is highly
variable,  depending  on climatic  factors  and  litterfall  rates.
Edmonds and  Mayer in. Bledsoe  (1981)  reported a  slight  initial
drop in sludge pH  following a  five inch  summer application, but
found that the pH  remained  well  above  soil  pH for  about one
year.  That high pH was reportedly due to slow decomposition and
lack of leaching.   In the four months following,  the  pH  of the
sludge  dropped  to a  value  below  that  of  the underlying  soil.
Low  sludge and surface  soil pH  are due  to  nitrification and
displacement of acidic H+ ions by other  cations  introduced by
the sludge (Edmonds and Cole,  1977).

     Based on the results of the aforementioned research and the
highly buffered nature of forest  soils,  it is unlikely that the
                               213

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small amount of sludge proposed  for  application to the Pilchuck
site would have any long term effects on soil pH.  Surface soils
can expect a temporary increase  in pH,  followed by a pH decline
with a final value near the original pH (Zasoski, pers. comm.).

Cation Exchange Capacity (CEC)

     The CEC may  be  defined as the ability of  a soil to adsorb
cations  and  is expressed  in millequivalents  per 100  grams of
soil.  CEC is  heavily  dependent  on soil pH as  well  as the type
and  quantity  of  clay  minerals  and  organic  matter.   Those
materials  are  usually negatively  charged and  provide exchange
sites for cations.  Because  of a higher clay  and organic matter
content,  surface   soils  generally have  a  higher  CEC  than  do
subsoils.

     Sludge contains  a  great amount of organic matter and sub-
sequently  has  a CEC  well  above  that  of  the  coniferous forest
soils on which it would be  applied.  As  the  sludge decomposes,
the CEC  of  the underlying  soil is likely  to  increase.  Edmonds
and Cole  (1977) reported that one  year  after  the application of
10 centimeters of  sludge to  a gravelly outwash  soil,  the CEC of
the  soil had  increased 30  percent  over pretreatment  levels.
Following  two  years  of  sludge  (3  percent solids)  application
Stednick and Wooldridge  (Sopper  and Kerr, 1979)  found soil CEC
increases of 31 percent, with the most dramatic increases in the
A  horizon.   The authors also found  no changes in the  type or
quantity of clay minerals in the  soil and  attributed CEC changes
to increases in the amount or form of organic colloids.

     The addition  of sludge  appears  to  significantly increase
the number  of  exchange sites  for  cations.  CEC  increases fol-
lowing sludge  applications  on the  Pilchuck sites would probably
be less than the 30 percent reported by Edmonds and Cole (1977).
Their  results  were  based  on a  10   centimeter  application  of
sludge; approximately four  times the  amount  of sludge scheduled
for application to the Pilchuck sites.

     The surface  soil  CEC  of the Pilchuck sites  is  higher than
that of the soils  investigated by Edmonds  and  Cole (1977).  The
CEC of  the surface layer  of the Winston  soil  on the  number  8
Pilchuck site,  for example,  is  about  29  meq/100  (Table  B-4) ,
which  is nearly  three  times  the  CEC  of the  site  studied  by
Edmonds and Cole (1977).  It is likely that sludge would cause  a
greater  CEC  increase in soils that  possess  a  low  initial CEC
(Zasoski, pers. comm.).

Mechanisms for cation movement

     Many of the  nutrients  required  for  plant growth  occur as
positively  charged  ions   (cations).   In  western  Washington
coniferous forests,  the  cations  are  conservatively  cycled with
only a  small percentage  lost from the system  via leaching.  In
                              214

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order for cations  to move through  the  soil profile, two things
must be present:

     1.   a mobile anion  to  maintain  electrical  neutrality in
          transport

     2.   a cation to displace the migrating cation

Cation losses from forest  systems  are most often limited by the
paucity  of  mobile anions  (Johnson  and  Cole,  1980) .    In the
coniferous  forests  of  western  Washington organic acids  and
bicarbonate  ions  appear  to  be   the  dominant  mobile  anion
responsible for cation movement  (Riekerk, 1978).  •

     Sludge adds both the potentially limiting mobile anions and
the  replacement  cations.   Following  applications  of  sludge,
nitrate  becomes   the  dominant  anion  responsible  for  cation
transport (Edmonds and Cole,  1976).  Sulfate and chloride anions
introduced through sludge application play minor but significant
roles  in  cation  movement.    White  phosphate,  another  anion
present  in  sludge,  appears  to  play  an  insignificant  role  in
cation leaching because  it is  rendered insoluble by iron oxides
in  the  lower B  horizon  (Sopper and Kerr  in  Sopper  and Kerr,
1979;  Wiklander,   1975).   Cations  commonly lost  via  leaching
include  sodium,  potassium,   magnesium  and calcium,  with  the
greatest losses associated with  calcium (Table B-l).

     The following factors are  likely  to  cause  cation leaching
rates to be greater  on  the Pack  forest site (Table B-l)  than on
the Pilchuck sites:

     1.   Sludge  depths at Pack forest were  about  four times
          those proposed for Pilchuck.

     2.   Pack  forest  soils  were  coarser  textured which  may
          allow greater cation  leaching  rates  than the finer
          textured soils (Edmonds and Cole, 1977) .

     3.   The trees on the Pack  forest site were much older than
          those at the Pilchuck  site.  Older stands  are known to
          uptake  less  nitrogen   (the  source  of  the  dominant
          mobile anion) than do  younger stands (Cole and Johnson
          in Heilman et al.,  1979).


Nitrogen Cycling

     In  an  unfertilized western Washington coniferous  forest,
nitrogen is conservatively cycled  and often limits tree growth.
The  vast  majority of  nitrogen  exists  as   organic  nitrogen and
other proteins which cannot be utilized by higher plants  (Figure
B-l) .
                               215

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to
I-"
a\
                                                    TABLE B-l



                   Elemental concentrations  (PPM) of C-Horizon  leachates  for  the  Pack Forest

                            demonstration site  (modified from Edmonds  and Cole  1977)

Control
(no sludge)
10 cm sludge
Percent
increase
NH,,-N
0.02

0.16
700

NO..-N P
0.10 0.03

19.30 0.06
19,200 100

S CL
1.4 4.8

1.5 49.6
7.1 933

Na
2.5

9.9
296

K Ca
0.9 31.2

2.6 52.5
189 68.3

Mg
0.8

14.5
1712.5

              Assumes:  Everett Soil series with a Douglas  fir  canopy.

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     A  small percentage  (about  one percent)  of  this  organic
nitrogen is  hydrolyzed by  heterotrophic organisms  through the
processes  of  mineralization  to  ammonia   (NH ) _ and  ammonium
(NH.+)  (Heilman  and  Gessel,   1963) .    Oxidation  of  ammonium
to  nitrate  (NO..-)   (nitrification)  occurs  slowly  due  to low
soil pH and paucity of the nitrifying bacteria necessary to make
the transformation.   Competition for the small  amounts  of N0_-
is  fierce,  with  bacteria utilizing  most of  this  anion.   Tne
remainder is  taken  up by vegetation and only  a  small amount is
leached from the soil.

     The addition of  one  inch  of dewatered sludge approximately
doubles the  amount  of nitrogen  in a western Washington glacial
outwash soil  of medium low  productivity  (Heilman in Heilman, et
al., 1979;  Henery and  Cole,  1983).   Approximately 78 percent of
this added nitrogen exists in organic form with the remainder as
ammonia or ammonium, depending  on the  pH (Henry  and Cole,   1983)
(Figure  B-l).    During   the    first   year   following   sludge
application,  approximately  20   percent  of the organic  nitrogen
may be  mineralized  (Henry and Cole, 1983) .   In  addition,   large
amounts of  the ammonia  would   lost  as  a  gas  (volatilization).
That  loss  would occur from  the lagoon,  (if one  were used) and
during  application  and after sludge  application.   Esitmates are
that  volatilization loss  is about  50  percent of the available
(NH,,  NH. + )  nitrogen  during the  first  year  (Henry and  Cole,
1983; EPA4,  1977) .

     Additional pathways  for  available nitrogen  include  plant
uptake,   soil    storage    or    nitrigication     (Figure   B-l).
Nitrification  rates   of  sludged  soils  may  be  greater  than'
unfertilized soils due to the following  factors:

     o    additional quantities  of ammonical nitrogen

     o    temporary soil pH increases

     o    increases  in the  population  of  nitrifying  bacteria
          (both   initial   populations   and   the   addition  of
          heterotrophic sludge  transported bacteria)  (Brewer et
          al. in Sopper and Kerr, 1979).

Increases in the nitrigication rate may  increase  leaching losses
of the  nitrate anion.  Leaching loss  estimates   range up  to 75
Ibs/acre,   (Henry  and  Cole,  1983)  depending  on tree  uptake,
precipitation,  bacteria  populations   and   a   number  of  soil
variables.

     The  potential   for   nitrate   leaching  should  decrease
dramatically  during  the  second year.   Mineralization  should
decrease to  about  3  percent  of the  total available  nitrogen
while uptake may  increase to about  150  Ibs/acre   (Henry  and Cole
1983).   This  would   result   in  less  nitrate   available  for
leaching.   A simplified nitrogen  balance for years  two,  three
and four following sludge application is presented in Table B-2.
                              217

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      NITROGEN CYCLE OF AN UNFERTILIZED CONIFEROUS FOREST
          Organic
          Nitrogen
          1980 Ibs
                                              Leaching Loss
                                                 0.4 Ibs
      FATE OF SLUDGE-ADDED NITROGEN AFTER YEAR 1  {1* SLUDGE)
            Soil  Storage
             200 Ibs
Leaching Loss
  0-75 Ibs
Note: All values are approximate Ibs/acre/year.
SOURCE: VALUES OBTAINED FROM COLE AND JOHNSON IN HEILMAN (1979) AND EDMONDS AND
      COLE (1982) FOR GRAVELLY OUTWASH AND A DOUGLAS FIR STAND.
                       FIGURE B-1
       Nitrogen  Cycles of Unfertilized Soil
     (Conceptual  Model ,  Not Actual Values)
                              218

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                       Table B-2

    Nitrogen Balance for Years Two, Three and Four
       Following a One-Inch Sludge Application
       To a Western Washington Coniferous Forest
Year Two
     Available N (storage
     Mineralized N
     Tree Uptake
     Volatilized
     Leached
 200 pounds/acre
+ 50   "     "
-150
   0   "     "
  25

  75  pounds/acre stored,
      1000 pounds/acre
      organic-N remains
Year Three
     Available N (storage
     Mineralized N
     Uptake
     Volatilized
     Leached
  75 pounds/acre
+ 30   "
-105   "     "
   0   "     "
 	0   "     "

   0  pounds/acre stored,
      970 pounds/acre
      organic-N remains
Year Four
     Available N (storage
     Mineralized N
     Uptake
   0 pounds/acre
+ 30
- 30

   0  pound.s/acre stored,
      940 pounds/acre
      organic-N remains
From:  Metro 1982d
       All values are approximate
                          219

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Heavy Metal Concentrations and Mobility

     Unfertilized forest soils of western Washington contain low
concentrations of heavy  metals.   Values such  as  those reported
for  the  Pilchuck demonstration  site  (Tables  B-3 and  B-4)  are
typical for the region.

     Digested sludge contains metal concentrations several times
those found in the soil  (Table B-3) and movement of those metals
into the food  chain  or groundwater represents  one  of the major
concerns regarding land disposal of sludge.  Heavy metals may be
essential  plant   nutrients,  such  as  copper  (Cu),   zinc  (Zn) ,
manganese  (Mn) and iron  (Fe)  or  non-essential elements that can
cause  toxic  reactions  to  plants  and animals  such  as  cadmium
(Cd), nickel  (Ni)  and lead  (Pb).   Information concerning total
allowable  loadings of  these  metals can be  found  in DOE (1982).
Table 2-3 gives heavy metal concentrations for Metro sludge.

     In order  for metals to  move  into vegetation  or the ground-
water,   they   must   become   soluble   in  the  soil   solution.
Solubility depends  on a  number  of  factors  including  soil  pH,
CEC,  amount  of  metal  added,  soil  aeration  and  the metal  in
question.

     Soil pH is  the  most important of these factors controlling
metal  solubility (EPA,  1977).   Low  soil  pH' s (below  6.5)  can
weaken  the bounds   between  metals  and  complexing  agents  and
increase the mobility  of metals  (EPA, 1977).  The Environmental
Protection Agency (EPA, 1979c)  (DOE,  1982a) requires that the pH
of  soils used  for food chain crops or animal  feed  be above  6.5
if  sludge  with a cadmium concentration over  2 mg/Kg is applied.
Research  with  coarse  forest  soils   however,  has  found  that
significant quantities of metals can be adsorbed by soils with a
pH  as low as 4.5  (Levine, 1975).

     Heavy  metals can  be  immobilized  to  varying  degrees  by
oxides  and organic  matter.   The  relative efficiency of  these
compounds  in  immobilizing  metals was  identified  by  McLaren  and
Crawford (1973):  Mn  oxides    organic matter   Fe oxides   clay
minerals.   In the   coniferous  forests  of  western  Washington,
organic matter,  specifically fulvic  acids,  are important immo-
bilizers of metals.   These organo-metal complexes  may however,
migrate downward through the profile; especially in well aerated
soils  where  channels  of  increased  hydraulic  conductivity  may
develop  (Sidle and Kardos, 1977;  Ugolini  et al., 1977).

     The properties of the metal such as  valence state and ionic
radius also determine the proficiency with  which soil  binds  a
metal.  Copper and lead for example, are  the most  securely bound
to  organic soil  constituents  and  have  not been  found to  be
mobile  in  the soil  (Sidle and  Kardos,  1977; Williams  et  al.,
1980).   Zinc,  cadmium and nickel  appear  to be the  most mobile
heavy  metals   (Riekerk and  Zasoski  ir\  Sooper and Kerr  1979;
Williams et al.,  1980).
                              220

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     Table B-3.  Soil Samples Analysis  of the  Pilchuck Site

Parameter
Soil
Organic-N
NH -N
NCT+NO -N
Total P
Ortho-P
Total K
Total Solids
Volatile Solids
pK (saturated
paste)
Cadmium
Chromium
Copper
Mercury
Nickel
Lead
Zinc
Bacteria (Geometric Means)
Total Coliform

Fecal Coliform

Fecal Streptococci

Unit

%, dry weight
%, dry weight
%, dry weight
%, dry weight
%, dry weight
%, dry weight
%, wet weight
%, dry weight

—
mgAg
mgAg
mgAg
mgAg
mgAg
mgAg
mgAg

MPN/100 g
wet weight
MPN/100 g
wet weight
MPN/100 g
Mean
(n = 12)

0.312
.0061
.0060
.26
.023
.054
77
20

5.6
1.6
40
13
.22
45
21
59
c
.36 x 10
2
<.38 x 10
3
<.33 x 10

Minimum

0.52
.0009
.00051
.086
.0052
.035
56
9

5.0
.9
29
9
.14
25
9
41
?
.79 x 10
2
<.2 x 10
2
<.2 x 10

Maximum

1.31
.010
.017
.726
.051
.084
88
45

6.4
2.3
59
17
.40
65
42
74
-j
.24 x 10
7
.24 x 10
5
.7 x 10
Viruses - None detected in 12  soil samples tested  (<2 PFU/100 g,  wet weight)

Parasites - Giardia found in 2 of 8 soil samples tested (130/liter)

Chlorinated Organics - None detected in 8 soil samples tested
NOTE:  MPN =  Most probable number
       PFU =  Plaque forming unit
       <   =  Less than

SOURCE:  Metro 1983d.
                                      221

-------
                     Table B-4.  Soil Samples Analysis Results of the Pilchuck Site
KJ

—


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            SOURCE:   Metro 1983d.

-------
     In general, researchers have not  "ound metals introduced by
sludge to move below the top few inches of soil.  Parker et al.,
(1978) reported that over 95 percent of the added Pb, Cu, Zn and
Cd remained within 25 cm of the surface.  Williams et al. (1980)
found that concentrations  of  Pb,  Cu,  Zn, Cd,  chromium (Cr)  and
mercury  (Hg)  reached background levels 10 cm  below the sludge.
Locally, Henry  and Cole  (1983)  found  extractable  metal levels
slightly above control  levels  at  the 80 cm depth'.  These higher
levels did not,  however,  represent  a  significant increase  over
control levels (Henry and Cole 1983) .

     Total  metal  accumulation  following extended  sludge  and
wastewater  application  has  also been studied.  Andersson  and
Nilsson  (1972) reported that  in 12  years of  sludge application
to agricultural land, nearly all of the Mn,  Zn, Cu,  Nr, Pb,  Cd,
Cr, Hg,  arsenic,  selenium  and  cobalt remained  in the  top  20 cm
of  soil,  with  only  small amounts  taken up  by vegetation  or
leached from the system.


Organic Toxins

     Sludge  may  contain  trace  amounts  of  a  number   of  toxic
organic  chemicals.   These  chemicals   include  a   number   of
chlorinated hydrocarbons and poly  chlorinated  biphenyls (PCBs).
A  complete  list  of  these  compounds  and  their levels  in  Metro
sludge  are  found in  Appendix  A.    Research  on the  behavior  of
these toxins in the environment is relatively incomplete.

     Land application of sludge exposes  the organic  toxins  to
the following processes:

     o    volatilization
     o    plant uptake
     o    runoff in surface water
     o    movement into the groundwater
     o    adsorption by soil constituents
     o    degradation by microbial or photochemical action

     Two factors  favor  the  retention of the  toxins  in  the  upper
soil  layers:   the low  water solubility of toxins in  water  and
the strong adsorption by surface soils (Darce  in  Bitton et  al.,
1980).  Bailey and White  (1970)  found most  toxins-were adsorbed
in the  surface  soil, with only a  few  reaching depths  of  30-60
centimeters.   Soil  agents  responsible  for  adsorption include
organic  matter,  metal  oxides  and  clays   (Lichtenstein,  1971).
The effectiveness of the  adsorption  depends  on  the  number  of
functional groups, which  include phenolic and  carboxyl groups,
amines  and  amides.   Organic matter  contains  a large  number  of
these groups, and therefore, great adsorptive capabilities.

     Retention  of  the   chemicals   in  the  surface  soil  layer
increases  the  possibility of volatilization  or  degradation.
Volatilization of these chemicals  occurs readily  only at  the
soil  surface  and  may involve  only a  small  percentage of  the
amount applied (Lichtenstein,  1971).  Volatilization rates vary,
                              223

-------
depending on the  molecule  and a number of  soil  and atmospheric
conditions, but the  insecticide  aldrin  appears  to be one of the
most volatile (Lichtenstein, 1971) .

     Degradation  may occur either  through raicrobial  or photo-
chemical action.   Although microbial transformations  are slow,
some bacteria  and fungi  are  capable  of  degrading  the  complex
molecules  into  less  toxic forms  (Menzie,   1972).   Ultraviolet
irradiation is capable  of  transforming  the  insecticide dieldrin
under certain conditions (Menzie, 1972).

     In  general,   plants   do  not  uptake   large  quantities  of
organic toxins (Pahren  et  al.,  1979).   This is  due to the large
size of  the  molecules and their low water  solubility.   Moza et
al.  (1979) found  very low uptake rates of  PCBs  by spruce trees
(Picea abies) .   Certain root  crops  however, may  absorb  organic
toxins (Lichtenstein, 1971) .
                              224

-------
	Appendix C
 Silviculture History—Pilchuck Tree Farm Demonstration Site

-------
                         Appendix C

            Silvicultural History Pilchuck Sludge
                      Application Sites

     The following information pertains to the silvicultural
history of the Pilchuck Demonstration Sites:
Northern Site
     1970 - site scarified
     1971 - site planted to 1,700 trees/acre Douglas-fir
     1977-1979 - harvest of a portion of the stand for Christmas
      trees
     1980 - precommercial thinning to 350-400 stems/acre
     1982 - aerial spraying with bravo 500 fungicide for Swiss
      Needle cast fungus
Southern Portion of Northern Site
     1976 - site scarified
     1976-1977 - site planted 600 trees/acre Douglas-fir
     1978 - foliar aerial spray with 2-4D and 2-4-5T herbicide
Southern Site
     1959 - site planted 500 stems/acre Douglas-fir
     1963, 1965 - site interplanted with Douglas-fir-due to
      mortality
     1969 - foliar aerial spray with 2-4D
     1979 - precommercial thin to 350 stems/acre
     1981 - commercial thin, to 300 stems/acre
                              225

-------
226

-------
	Appendix D
 Endangered and Threatened Species—Pilchuck Tree Farm
                                  Demonstration Site

-------
             Appendix D
 Endangered and Threatened Species -
Pilchuck Tree Farm Demonstration Site
                  227

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228

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DHNSPELLMAN                                >plT^aiM/                                 FRANK LOCKARD
  Governor                                   N%J^/                                    Director

                                      STATE OF WASHINGTON

                                  DEPARTMENT OF CAME
                   600 North Capitol Way, CJ-n  •  Olympia, Washington 98504 •  (206)753-5700

                                       December 22, 1982
        Jones and Stokes Assoc.  Inc.
        1802 136th Place N.E.
        Bellevue, WA  98005

        SUBJECT:   Pilchuck Project Site

        Dear Mr.  Denman:

       We have completed a review of the Natural Heritage uata Base for informa-
       tion on significant natural  features in the study area.  At this time we
       do not have information  on special  animal species in trie immediate area.
       Since information is being added to  the files doily, -i search at some
        later date may be worthwhile.  Please keep this in -iinti when long-term
       project planning is involved.

       This response  is not to  be construed as a complete inventory of the project
       area and  does  not eliminate  the need or responsibility to conduct more
       thorough  research.   Data in  the Natural Heritage Data Base are limited to-
       significant observations of  species  of concern only.  Significant observa-
       tions are primarily comprised of breeding site aata, out depending upon
       the species, wintering areas  and regular concentrations are also entered.
       For some  particularly  rare or secretive species, observations of individuals
       are considered sufficiently  significant for data entry.

        If your office should  publish or distribute any of tha information presented
       here, please cite the  Natural Heritage Data System as follows:

                        Natural  Heritage Data  System
                        Department of Natural  Resources and
                          Department of Game - Nongame  Program
                        c/o The Evergreen State College
                        3109 Seminar Building, TA-00
                        Olympia, Washington  98505

        I  hope this presentation will be useful to you.   If you have further
       questions or concerns, please feel  free to contact me at  (206)  754-1449
       or SCAN 8-235-1449.

                                              Very truly yours,

                                              THE DEPARTMENT OF GAME



                                              Kelly R.  McAllister
                                              Nongame Wildlife  Program

       KRMihl
                                            229

-------
                      Department of  Natural Resources
                                                                            BRIAN BOYLE
                                OLYMPIA, WASHINGTON                   Commiuioner of Public Und,
                                         98504
                        WASHINGTON NATURAL HERITAGE PROGRAM
                          3111 Seminar Building (SE 3109)
                            The Evergreen State College
                             Olympia,  Washington 98505
 December 20, 1982
Mr.  Robert A Denman
Jones  and Stokes Associates, Incorporated
1802-136th Place N.E.
Bellevue, Washington   98005

Subject:  Pilchuck project site

Dear Mr. Denman:

V.-i have completed a search of the Natural Heritage Data System for your study area.
Ac this time we do not have data on special plant species or high quality native
plant communities near the area you specified.   Information on special animal species
will be provided, under separate cover, by the  Washington Department of Game,
Nongame Program.

Please be aware that the Data System is not exhaustive.  There may be special plants
or native plant communities occurring in your study area that we do not yet know
about.  Therefore, this information is not to be taken as a complete inventory of
the project area and does not eliminate the need or responsiblity to conduct more
thorough research.

Please cite the Natural Heritage Data System, as follows if this letter is referenced
in publications or correspondence by your office.

           Natural Heritage Data System, 1981.
           Washington Natural Heritage Program  and Washington
           Department of Came,  Nongame Program.   Mail Stop SE 3109,
           The Evergreen State  College, Olympia, WA  98505.

I hope this information will be useful to you.   Please feel free to contact me
at (206) 753-2449 (SCAN:  8-234-2449), if you have any further questions.

Sincerely,
Elise Augenstein
Data Manager/Botanist

EA/cd
                      Equal Opportunity/Affirmative Action Employer

                                       230

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pNES & STOKES ASSOCIATES. INC. / 1802 136TH PLACE, NE  / BELLEVUE, WA 98005           206/641-3982
     December  14,  1982
     Kelly McAllister
     Washington Department of Game,
     Nongame  Program
     Evergreen State College
     3109 Seminar Building
     Olympia,  WA  98505

     Dear Mr.  McAllister:

     Would you please do an inventory search to determine
     if  there are any rare and/or endangered animal species
     present  on the Pilchuck project site.  The site is
     located  north of Arlington, T32N, R5E' sections 23,24,
     25,26,35,36 and R6E sections 19,30.  A map showing the
     project  site is enclosed.

     The bill for the search should be sent to:

                Jones & Stokes Associates, Inc.
                1802 136th Place, N.E.
                Bellevue, WA  98005

     If  you need any further information, please feel free to
     contact  me at 641-3982.  Thank you for your cooperation.
     Robert A.  Denman

     RAD/as
     Enclosure
                                      231

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JONES & STOKES ASSOCIATES. INC.  /  1802 136TH PLACE, NE / BELLEVUE. WA 96005            206/641-3982
       December 14, 1982
       David Mladenoff
       Natural Heritage Program
       3111 Seminar Building
       Evergreen State College
       Olympia, WA  98505

       Dear Mr. Mladenoff:

       Would you please do an inventory search to determine
       if there are any rare and/or endangered plant  species
       present on the Pilchuck project site.  The site  is
       located north of Arlington, T32N, R5E sections 23,24,
       25,26,35,36 and R6E sections 19,30.  A map showing
       the project site is enclosed.

       The bill for the search should be sent to:

                 Jones & Stokes Associates, Inc.
                 1802 136th Place, N.E.
                 Bellevue, WA  98005

       If you need any further information, please  feel free  to
       contact me at 641-3982.  Thank you  for your  cooperation.
       Sincerely,
                  /i
                  q
       Robert A. Denman
       RAD/as
       Enclosure
                                        232

-------
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
     M/S 443
Mr. Joseph Blum
U. S. Fish and Wildlife Service
Endangered Species Team
2625 Parkmont Lane
Olympia, Washington  98502

Dear Mr. Blum:

In accordance with Section 7 (c) of the Endangered  Species Act of  1973,
we are requesting information on the existence of endangered or
threatened wildlife species or critical habitats  in the  vicinity of
Arlington, Washington.

The Environmental Protection Agency is preparing  an Environmental
Impact Statement on a long-range sludge management  plan  for the
(Municipality of Metropolitan Seattle (Metro),   Included  in the analysis
is a proposed demonstration project at the Pilchuck Tree Farm near
Arlington.  A brief project description and maps  are enclosed.

If you need any further information, please do not  hesitate to contact
me at (206) 442-1834.

Sincerely,
Kathryn M. Davidson
Project Monitor

Enclosure
                                   233

-------
         United States Department of  the Interior

                   FISH AND WILDLIFE SERVICE

                          Endangered Species
                     2625 Parkmont Lane S.W., 6-2
                          Olympia, WA 98502
February 15, 1983

Ms. Kathryn M.  Davidson
Project Monitor
Environmental Protection  Agency
1200 Sixth Avenue
Seattle, Washington  98101

Refer to: 1-3-83-SP-128
Your ref:  M/S 443

Dear Ms. Davidson:

As requested by your letter, dated January 12, 1983,  I  have attached
a list of endangered and  threatened species (Attachment A)  that
may be present in the area  of the proposed Sludge Management Demon-
stration Project - Pilchunck Tree Farm, Snohomish County, Washington.
The list fulfills the requirement of the Fish and Wildlife  Service under
Section 7(c) of the Endangered Species Act of 1973,  16  U.S.C.  1531,
et seq.  Your Endangered  Species Act requirements are outlined in
Attachment B.

Should your biological assessment determine that a listed species
is likely to be affected  (adversely or beneficially)  by the project,
your agency should request  formal Section 7 consultation through
this office.

Even if your biological assessment shows a "no effect"  situation,
we would appreciate receiving a copy of your assessment for our
information.  If you have any additional questions regarding your
responsibilities under the  Act, please contact Mr. Jim  Bottorff,
Endangered Species Team Leader, (206) 753-9444, FTS 434-9444 at
the following address:
                     U.S  Fish and Wildlife Service
                     Endangered Species Team
                     2625 Parkmont Lane S.W.,  Bldg.  B-2
                     Olympia, WA  98502
IfV'
                                                                 FEB 14 1983
                                                                               0
                                 234

-------
Your interest in endangered species is appreciated.

Sincerely,
 •—  /   'V, <4-S-'
 im A. Bottorff  / r/
Endangered Species Team Leader

Attachments

cc:  RO (AFA/SE)
     ES, Olympia
     WDOG, Non-Game Program
     WNHP
                                  235

-------
       LISTED AND PROPOSED ENDANGERED AND THREATENED SPECIES AND
   CANDIDATE SPECIES THAT MAY OCCUR WITHIN THE AREA OF THE PROPOSED
     SLUDGE MANAGEMENT DEMONSTRATION PROJIC7 - PILCHUCK TREE FARM,
                     SNOHOMISH COUNTY, WASHINGTON
                             1-3-83-SP-128
                          Your ref:  M/S 443
LISTED:

Bald Eagle (Haliaeetus leucocephalus)  - wintering concentration of
eagles found along N. Fork Stillaguamish River near and downstream
from the project area.  Major concerns are:

1.   Loss of streamside habitat - perch sites

2.   Disruption of habitat and eagle activity during construction and
     operation of project facilities

3.   Contamination of eagle prey items downstream of project area.
PROPOSED:

None
CANDIDATE:

None
Attachment A
                                 236

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         FEDERAL AGENCIES' RESPONSIBILITIES UNDER SECTIONS 7(a) and (c)
                          OF THE ENDANGERED SPECIES ACT


 SECTION 7(a) - Consultation/Conference

      Requires: 1) Federal agencies to utilize their authorities  to carry out
      programs to conserve endangered and threatened species;
                2)  Consultation with FKS when a Federal  action may affect a listed
      endangered or threatened species to insure that any action  authorized, funded
      or carried out by a Federal agency is not likely to jeopardize the continued
      existence of listed species or result in the destruction  or adverse modifica-
      tion of Critical  Habitat.  The process is initiated by the  Federal  agency
      after they have determined if their action may affect (adversely  or bene-
      ficially) a listed species; and
                3)  Conference with FKS when a Federal  action is  likely to jeopardize
      the continued existence of a proposed species  or result in  destruction or
      adverse modification of proposed Critical Habitat.

 SECTION 7(c) - Biological  Assessment for Construction  Projects

      Requires  Federal  agencies or their designees to  prepare Biological  Assessment
      (BA)  for  construction projects]/ only.   The  purpose of the  BA  is  to  identify any
      proposed  and/or listed  species which  are/is  likely  to be affected by a  con-
      struction project.   The process  is initiated by a Federal  agency  in  requesting
      a  list  of proposed and  listed threatened and endangered  species (List attached).
      The BA  should  be  completed  within  1£0  days after  its initiation (or within
      such  a  time  period as  is  mutually  agreeable).  If the BA is  not initiated
      within  90 days  of receipt of the species  list, please verify the accuracy
      of the  list  with  our  Service.   No  irreversible commitment  of resources  is to
      be made during  the BA process  which would  result  in violation of the require-
      ments' under  Section 7(a)  of the  Act.   Planning, design,  and  administrative
      actions may  be  taken; however,  no  construction may begin.

      To complete  the BA, your  agency  or  its designee should:  (1)  conduct an on-
      site  inspection of  the  area  to be  affected by the proposal which may include a
      detailed  survey of  the  area  to determine  if the species  is present and whether
      suitable  habitat  exists for either  expanding the existing  population for
      potential  reintroduction  of the  species;  (2) review literature and scientific
      data to determine species distribution, habitat needs, and other biological
      requirements; (3)  interview experts including those within FWS, National Marine
      Fisheries Service, State  conservation departments, universities and others who
      rr.ay have data not yet published  in  scientific literature;  (4) review and analyze
      the effects of the proposal on.the  species in terms of individuals and populations,
      including consideration of cumulative effects of the proposal  on the species and
      its habitat; (5) analyze  alternative actions that may provide  conservation measures;
      and (6)  prepare a report  documenting the results, including  a  discussion of  study
      methods  used, any problems encountered, and other relevant information.   Upon
      completion, the report should be forwarded to our Area  Manager.
     I/  "Construction Project" means any major Federal  Action which  sianificantly
         affects the quality of the human environment (requiring an Eisj  designed
         primarily to result in the building or erection of man-made  structures
         such as dams, buildings, roads, pipelines,  channels, and  the like.   This
         includes Federal  actions such as permits,  grants, licenses,  or other forms
         of Federal  authorization or approval which  may  result in  construction.

ATTACIiKENT B
                                       237

-------
238

-------
	Appendix E
 Cultural Resources—Pilchuck Tree Farm Demonstration Site

-------
             Appendix E
Cultural Resources Pilchuck Tree Farm
         Demonstration Site
                   239

-------
240

-------
ilNES & STOKES ASSOCIATES. INC. / 1802 136TH PLACE, NE / BELLEVUE, WA 98005

                                    January  10,  1983
206/641-3982
       r. Robert Whitlam
       'ffice of Archaeology and Historic Preservation
      111 West 21st Avenue, KL - 11
      Olympia, WA  98504

      Dear Dr. Whitlam:

      Subjects  Environmental Impact Statement  (EIS)
                Metro Sludge Management Plan

           During November, 1982, I spoke with you briefly  about
      needs to conduct an archaeological survey of proposed sludge
      application sites in Arlington, Washington.

           The Municipality of Metropolitan Seattle  (Metro)  is
      proposing to initiate a sludge application demonstration
      project on 72 -acres of land on the Pilchuck Tree Farm, Arlington,
      Washington.  Jones & Stokes Associates, Inc. is contractor
      to the U. S. Environmental Protection Agency for the  preparation
      of an EIS on Metro's long-range sludge management plan.   As
      a first phase of that plan, Metro desires to demonstrate
      the spray application of liquid sludge onto forest  lands.

           I have attached maps showing the location of the 72
      acre site and a description of the proposed sludge  application
      program.  The only possible ground-disturbing activity as
      a part of the project would be associated with the  construction
      of a sludge storage lagoon.

           At your earliest convenience I would like to know if
      a survey or cultural resources report will be necessary and
      if so required, could that task be accomplished during the
      design stage of the project.

           If you e^e in need of any additional information, please
      do not hesitate to contact me.

                                    Sincerely,
                                    Jonathan  H.  Ives

      cc:  K. Davidson, U. S. EPA/Environmental  Evaluation Branch

                                       241

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JOHN SPELLMAN                                V^J^if'y                                 |ACOB THOM^S
  Governor                                    N^.o^'                                     Director

                                       STATE OF WASHINGTON

                 OFFICE  OF  ARCHAEOLOGY AND HISTORIC  PRESERVATION
                 777 West Twenty-First Avenue. KL-11  •  Olympia. Washington 98504  •  (206; 753-4011


                                                  January 14,  1983
               Mr.  Jonothan H. Ives
               Jones & Stokes Associates, Inc.
               1802 136th Place N.E.
               Bellevue, WA 98005

                                                  Log Reference:  367-C-KI-03

                                                  Re:  Metro Sludge Management Plan

               Dear Mr. Ives :

               We have  reviewed  the  materials  forwarded to us for the above referenced
               project.  Based on  the  results  of our  records  searches,  consultations,
               and  the materials  provided  for our  review,  we  recommend  professional
               cultural  resource surveys  of the  project area  be conducted  prior to
               further action.

               The above comments are based on  the information available at the time of
               this  review.  Should  additional information  become available,  our as-
               sessment may be revised.  Please indicate the log reference number noted
               above  in further  communications  concerning  this  project.   A  copy of
               these comments should be included in subsequent environmental documents.

                                                  Sincerely,
                                                  Robert G.  Whitlam, Ph.D.
                                                  Archaeologist
               dj
               Enclosure
                                                242

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CULTURAL RESOURCE ASSESSMENT PROPOSED SLUDGE FACILITIES

         AT THE PILCHUCK TREE FARM, ARLINGTON,

             SNOHOMISH COUNTY,  WASHINGTON
                   by Carol  Kielusiak
                     Submitted to

               Jones 6 Stokes Associates
             Office of Public  Archaeology
          Institute for Environmental  Studies
               University of Washington
                        Seattle


                     February 1983
                         243

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                             TABLE OF CONTENTS











Project Location	   1




Proposed Act ions	   1




Environmental Setting	   3




Cultural Setting	   1»




Results of Literature/Archival Review	   8




On-s i te Assessment	   9




Resu 11 s	  11




Recommendat ions	  12




References Cited	  1l»
                               LIST OF MAPS








MAP 1.  Vicinity map and location of isolated finds	  2




MAP 2.  1890 GLO Plat Map	  fc
                                     i i
                                    244

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PROJECT  LOCATION




    The  proposed  sludge facilities  are  located  in  the   Armstrong   Tract   of




the Pilchuck Tree Farm, approximately three miles  northeast  of  Arlington  in




Snohomish  County.  The present  study  area   includes:    (1)   the   proposed




sludge   application sites, which  lie on  a gently sloping plateau bounded  by




the North  Fork of the Sti1laguamish River and two  of  its tributaries,  Kunze




and  Rock   Creeks, situated mainly  in T  32N, R  6E, SW  1A, Sec. 19, and (2)




the sludge lagoon site which  is situated about  1.6 kilometers due  west in T




32N, R 5E,  SW 1A, SW 1A, Sec. 2k,  W.M. (Map  1).









PROPOSED ACTIONS




    The  Pilchuck  Tree   Farm demonstration sludge application project is a




joint effort to  improve forest  productivity of  70  acres  (28  Hectares)  of




land  near  Bryant  and   Arlington,  Washington,   through  the  addition of




dewatered  municipal sludge to forest soil.  This is part  of  a  continuing




effort   to  improve techniques for managing timber  production on over 13,000




acres (5,260 Hectares) of  land  in Snohomish and Skagit Counties.




    Facilities required for application of  sludge  at  the  Pilchuck  si.te




include  a  storage  and   rehandling  lagoon,   an  access  and distribution




network, security equipment, personnel facilities, and equipment repair and




cleaning   facilities.   A  number  of  monitoring  wells and soil   and water




monitoring  stations are also required.




    The proposed lagoon has approximate surface dimensions of  135  by  190




feet  (1»1   by 58 meters), and a maximum design  sludge depth of 15  feet (A.5




meters).   Additional  area would be required for the external berm  slope and
                                   245

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CTl
                                                   ARLINGTON  EAST. WASH.
                                                      f<» 4 M»N\iviut is GUADHANOLE
                                                              S--WI2200/7 5

                                                                1956
                                                                                                     UOAC,B»SC,l [ LOCATION
                    MAP I.  Vicinity map of project  area showing locations of  Isolated finds  (numbered)
                            in relation to  (a)  lagoon site and (b) application area.

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for  a  roadway  around  the  lagoon.   A  6-foot chain link fence would be




provided for access control.  Other features include an access and  dumping




area  for  long-haul  trucks, a rehandling area for loading the application




vehicles, maintenance access, erosion  protection,  a  leachate  collection




system, and an adjacent monitoring well.









ENVIRONMENTAL SETTING




    The  project  area  is situated on a tract of land which is bordered by




the foothills of the North Cascades Mountains on the north, and  the  North




Fork   of  the  Sti1laguamish  River  to  the  south.   The  topography  is




characterized  by  plateaus  bordered  by  steep  gorges  incised  by   the




Sti11aguamish River and tributary creeks.




    The geology of the area consists of glacial sediments, deposited during




the most recent glaciation  (the  Vashon),  which  overlie  bedrock.   Soil




studies  recently  conducted  by  CH2M Hill (U.S.E.P.A. 1983)  indicate that




soils in the project area consist of Ragner Series (sandy loam overlaying a




loamy  sand),  except  on the bluff "situated between Kunze and Rock Creeks,




where Winston Series (loam above a gravelly sand) prevails.




    The natural patterns of vegetation which  are  characteristic  of  this




area  of the Puget Sound Lowlands have been somewhat altered in the project




area by si 1vicultural  activities.  A brief history of these activities,  in




a portion of the project area, is summarized below.




    The  northern  portion  of the northernmost sludge application area was




scarified in 1970 and  planted to  1700  Douglas  Fir  trees  per  acre  the




following  year.   From 1977-1979, a portion of the stand was  harvested for




Christmas trees and in 1980,  the  stand  was  precommercially  thinned  to
                                    247

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350-^00 stems per acre.  The southern portion of th?s site was scarified in




1976 and. In 1976 and 1977, 600 Douglas Fir trees were planted per acre.




    The sludge applications site, which lies to the south, was planted with




500  Douglas  Fir  stems  per acre in 1959.  In 1963 and 1965 this area was




interplanted with additional trees because of  mortality.   The  stand  was




precommercial1y  thinned  to 350 stems per acre in 1979 and two years later




was commercially thinned to 300 stems per acre (U.S.E.P.A. 1983).




    Natural vegetation has reclaimed the area in varying degrees so that an




occasional cedar (Thuja plicata) and alder (Alnus rubra) can be found among




the stands of Douglas Fir.  The understory, which is quite dense In much of




the  study  area.  Includes  native  blackberry  (Rubus  urslnus),  bracken




(pteridium aquilinum),  sword  fern  (Polystichum  muni turn),  Oregon  grape




(Berberis  nervosa),  salmon  berry  (Rubus spectabi1 is), salal  (Gaultheria




shallon), devil's club (Oplopanax horridum), etc.









CULTURAL SETTING




    The following ethnographic descriptin  is  primarily  taken  from  Lane




(1973)-   The  project  area  is  situated  within  the  territory occupied




ethnographically  by  the   Sti1laguamish   Indians.     Relatively   little




documentary  information is available regarding their traditional lifeways,




but from the limited evidence that is available, it  is  obvious  that  the




Sti1laguamish  were  skilled fishermen and canoe handlers who relied on the




resources of the river and its tributary streams  for  their  staple  food.




Salmon  and  steel head  were  taken with a variety of implements, including




harpoons, weirs and traps.  The catch was eaten fresh or It was   smoked  or




dried for winter use.  Hunting is also mentioned as a subsistence activity.




as is berry picking.






                                   248

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                                      5


    Distribution of major villages appears to have been  along  the   river,

and  Lane  (1973)  mentions  that  the Sti1laguamish camped along tributary

creeks.  Dwellings were the split cedar bark type typical  of  other  Puget

Sound groups; they also used roughly built smaller dwellings.

    In  contrast  to their neighbors, the Sti1laguamish remained relatively

isolated from white influence until some years after the  Treaty  of  Point

Elliot.   After  a brief stay on the Holmes Harbor and Tulalip Reservations

in the years 1855-56, most of them were able  to  return  to  their  native

territory  and  continue  in  their  traditional patterns of settlement and

subsistence until the 1870s when settlers began to take up the land.

    While settlement of the Sti1laguamish Valley began at the mouth of  the

river  in  186^ and continued to push slowly upriver, the North Fork of the

Sti1laguamish was not considered particularly desirable for farming because

of the difficulty of navigation in this area of the river.   Apparently,  the

Indians were the only ones to successfully pole the river,  and  were  often

hired  to  transport  settlers  and  bring in supplies from Standwood.  The

following excerpt,  which  originally  appeared  in  the  Arlington  Times,

describes, quite picturesquely, early settlement along the upper river;
     Until the year l88A the North Fork of the Sti1laguamish River was
     called 'Starve-Out Valley,1  for the reason that up to  that  time
     all  the  settlers  were  bachelors,  who  went  in with packs of
     blankets and provisions, and by the time that a shake shanty  had
     been  built,  a few trees had been cut, the 'last bit of bacon in
     the pan, fried,1  the last batch of sour dough baked on the  coals
     in  a  cedar  board  fireplace,  the  packstrap  settler hailed a
     passing Siwash canoe and went to Stanwood  for   another  pack  of
     supplies.   Many  never  returned  and  the  places were taken by
     others, who in time abandoned them.   And  the   hopeful  bachelor
     came  and  the  hungry  bachelor went, until  a  woman demonstrated
     that a human being could not only exist on the   products  of  the
     North  Fork,  but  could  live  there for eighteen years and grow
     stouter all the time (Whitfield 1926:51?).
                                    249

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MAP 2.  1890 GLO Plat  Map of  project  vicinity,
                           250

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    The woman referred to  is  Mrs.  Collingwood,  whose   party   passed   the




proposed project area in l88*», on their way to  settle their claim.   As  they




came to the stretch of the Sti1laguamish River  which  borders   the   present




study  area,  they  stopped  and  "pitched their tents at the McEwan  place,




three miles up the North Fork, and took possession of an  abandoned bachelor




cabin...(Whitfield  1926:520).   The  McEwan  claim   is  located  on the  1890




General Land Office Map (GLO 1890) on the east  side of the river, below  the




proposed sludge application site (see Map 2).




    By  the  early 1890s,  the general area was  well settled and  a number of




post offices and towns, such as Trafton, Oso, and Bryant were  established.




Present  day  Arlington  is  the  result  of  consolidation of Haller City.




platted in 1883 and Arlington (Phillips 1978:8-9).  The plat  of  Arlington




was  filed on March 15, 1890, and was incorporated in 1903.  Arlington soon




became the commercial and  industrial center of  this dairying, farming,   and




timber area (Whitfield 1926:537).




    The   extension  of  the  Northern  Pacific  Railroad  to  include   the




ArlIngton-Darrington Branch was completed about the end  of  May  1901,  an




event  which caused a population influx and provided for  increased interest




in the timber and agricultural industries in this vicinity (Local Committee




of Pioneers 1906:301, 362).




    A  survey  conducted by the General  Land Office after the coming of  the




railroad reveals that the portion of the study  area  proposed  for  sludge




application  was,  at  that  time,   claimed  by  George W. Kunze, hence  the




probable origin of the name Kunze Creek.  The application area also touches




a  portion of what was the C.  H.  Cobb and palmer Land and |nv. Co. and part
                                   251

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                                      8






of  the  claim of James Scanty. "Indian", as well as a small portion of  the




Wisconsin Timber Co. Land.




    The proposed sludge lagoon site was  then  Port  Blakely  Mill  Company




property.  The present Darrington road, which is located about a mile  south




of the study area, appears to  follow  the  route  of  an  old  wagon  road




(Anderson Map Co. 1910).



    The  area today continues to maintain farms and dairies in the alluvial




plains of the river and the study area itself has  been  incorporated  into




the pilchuck Tree Farm.








RESULTS OF LITERATURE/ARCHIVAL REVIEW



    The  records  on  file  at the State Office of Archaeology and Historic




Preservation and at the Office of Public  Archaeology  were  consulted   for




information  on  known cultural resources within the study area.  There  are




no properties  within  the  study  area  which  are  currently  listed,  or




considered  to  be  eligible  for  listing, on either the State or National




Registers of Historic places.




    The Washington State Archaeological  Site  Survey  Records  locate   the




nearest  recorded  archaeological  site (A5-SN-63) about five kilometers to




the south, between Jim Creek  and  the  Sti1laguamish  River.   Apparently,




while  a  number  of  cultural  resource studies have been conducted on  the




South Fork of the Sti1laguamish (e.g., Thomson 196lj Kidd 196A;  and   sites




recorded  by  Mattson in 197^, 1980 and by Qnat in 1979), none of them have




extended onto the North Fork.  These investigations reveal that  the   South




Fork  area  contains  a  high  density  of archaeological sites which  yield




artifact  assemblages  assignable  to  the  controversial  "Qlcott"  phase.
                                   252

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possibly  dating  to  an  early period.  Many of these sites are  located on




terraces, above  major  rivers  (Stilson  and  Chatters  1981 : H-21 ).   The




physiographic  setting  of the proposed study application area suggests the




possibility for the presence of such remains.




    Ethnographic literature  review  revealed  that  the  nearest   recorded




villages  in  the  study  area  are  near Trafton (T 32N, R 6E, Sec. 20 and




around Arlington (T 3lN, R 5E, Sec. 21), and, in 1952, a  tripod  weir  was




noted  about  four  miles  above  Arlington,  on  the  North  Fork  of  the




Sti1laguamish River (Lane 1973).




    Perusal  of  General  Land  Office  1890  plat  maps  show  that  early




settlements were situated along the banks of the river, where rich alluvial




soil was available for farming, rather than on the  high  terraces  of  the




study area (Map 2).









ON-SITE ASSESSMENT




    Field  reconnaissance of the proposed sludge lagoon location and sludge




application sites was conducted on February 10 and  11,  1983  by  Ms  Joan




Robinson  and Ms Carol Kielusiak, Staff Archaeologists at the University of




Washington's Office  of  public  Archaeology.   Survey  tactics  varied  in




different portions of the study area, depending on access,  extent of ground




visibility, and extent of previous ground  disturbance.   Greatest  efforts




were   expended   on  those  portions  considered  to  be  especially  site




sens it ive.




    Reconnaissance of the proposed sludge application  sites  consisted  of




walking  the  edges  of  the  bluffs  above Rock Creek, Kunze Creek and the




Sti1laguamish River.  These bluff edges had remained relatively undisturbed
                                     253

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                                       10






as  evidenced  by  the  presence of old growth timber and absence of  recent




Douglas Fir plantings.  It does appear that the  soil had been disturbed   in




some  areas,  possibly as a result of  scarification.  Understory vegetation




was dense  in some areas, and ground cover  included grasses, moss and  duff.




Slash  piles  also littered the way, but traverse was possible.  Due  to  the




high potential for archaeological remains  in these areas, every five  to  ten




meters  surveyors  cleared  an  area   to   soil,  measuring at least 50 X  50




centimeters.   Ground  visibility  was  also  provided  by  animal  trails,




uprooted trees, and animal burrows.




    The  all-weather  road  which  bisects  the  application sites was also




checked for cultural remains.  Several attempts  were  then  made  to  walk




transects  parallelling  the  road  in the forested area.  However, it soon




became apparent that traverse through  the dense  undergrowth was  impossible




in some places and, in others, both time-consuming and unproductive.




    Survey  in  the interior area of these plateaus was limited, therefore,




to walking existing paths, trails and  access roads which bisect the  areas,




generally  at  an  angle perpendicular to the all-weather road.  A total of




ten of these were walked,  six in the northern area and four in the southern




area.




    The proposed sludge lagoon site had not yet been staked so its proposed




location was determined as nearly as possible from the  project  map.   The




area  surveyed  was  a  portion  of  a triangular shaped piece of property,




bordered on the east by the power line and on the west by  Access  Road  20.




The  southern  limit  was   160  meters  north  of  the  Road 20/21  fork and




extended,  in a northerly direction, for 192 meters.
                                   254

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                                       11






    Survey strategy consisted of walking  10  meter  transects   in   a   NW/SE



direction  until  the  area  was  covered,  checking  all  available ground




exposures and clearing a  50  X  50  centimeter  section  of  ground   cover




approximately  every io meters.  The history of siIvicultural activities  in




this area is not known, but the area appears to  be  extensively  disturbed




and burned Douglas Fir stumps and piles of burned slash are the remnants of




logging activities.  A few fir saplings are currently growing in  the  area




and ground cover includes moss, grass, ferns and duff.








RESULTS



    Artifacts  were  observed  and  collected at each of the areas surveyed




(Map l).  A total of seven bottle fragments, representing two bottles, were




found  at  the  proposed  sludge  application  site,  and  three artifacts,




incl'uding two cobble choppers and one flaked piece of basalt,   were  found




at  three  separate  locations within the proposed sludge application area.




The bottle fragments probably date from 1900-1920, based on  amythest  tint



and machine-made seams.  They are most likely associated with early logging




activities in the area.




    The other three  artifacts  include  two  calcareous  siltstone  cobble




choppers and one flaked piece of basalt-like material.  The cobble choppers




resemble "Olcott" artifacts in material type.  They are quite weathered and




have  attained  a  patina of light mottled gray as is characteristic of the




"Olcott" assemblage.  The flaked piece of  basalt-like  material  resembles




these  artifacts only in material  type. Their locations are given below and




shown on Map 1.
                                   255

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                                      12
     Location ls  Cobble Chopper, T 32N, R 6E, NE lA,  SW  1A.  Sec.
     79^within"  northern  sludge  application area along an existing
     skid road near T.B.M. #21, .5 kilometers southeast  of  northwest
     property gate and $3.6 meters east of Rock Creek.

     Location 2:  Flaked Basalt. T 32N, R 6E, NE 1A, SW 1A, Sec.  19,
     at extreme south end of northern sludge  application  site  on  a
     point overlooking the StJ1laguamish River at the end of an access
     road, .3 kilometers southeast of Location 1.

     Location 31  Cobble Chopper. T 32N, R 6E, NE 1A,  NW  1/4,  Sec.
     30,  withTiT  southern  sTudge  application  area at the end of an
     access road which forks off the all-weather road to the south, 13
     meters  west  of  the  edge  of  the  bluff  which  overlooks the
     Sti 1 laguamish River, near  T.B.M. fl\ and Well #3.

     Location 4;  Bottle Fragments. T 32N, R 5E, Sec. 24, situated  in
     theorganic  soil  layer   at the proposed sludge lagoon site, .3
     kilometers north of the crossroads and 10 meters west of the road
     which borders the power lines to the west.
RECOMMENDATIONS

    In  view  of  the  presence  of "Olcott-1ike" artifacts on the proposed

sludge application area, it  is  recommended  that  further  archaeological

consideration  be  given  to this particular portion of the project area as

these remains represent an as yet little understood phase in the prehistory

of the Puget Sound Region.

    As  it is quite likely that additional  remains are present, which could

not be  located  during  the  recent  reconnaissance  due  to  poor  ground

visibility,  we  recommend  that the project be allowed to proceed with the

stipulation that subsequent to  completion   of  access  roads  and  skidder

trails  in  the  sludge application areas as shown on Map 1, a professional

archaeologist walk these newly exposed  areas  to  locate  any  potentially

significant remains which may be uncovered.
                                   256

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                                      13





    Additionally,  if  in  the  course  of  construction  of  sludge lagoon




facilities, unanticipated cultural remains are encountered, work should  be




halted  in  the  immediate vicinity and the State Office of Archaeology and




Historic Preservation should be contacted immediately.




    This report should not be considered to be permission to  proceed  with




the  project  in  question.   It contains professional opinions on cultural




rewources which might be affected by the project.  This  report  should  be




submitted  to  the  appropriate review agencies for their comments prior to




the commencement of any ground disturbing activities.
                                   257

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                             REFERENCES CITED


Anderson Map Co.

  1910  Plat Books of Snohomlsh County - compilation.


General Land Office

  1890  General Land Office Plat Map, T 32N, R 6E; T 32N, R 5E   and   Survey
        Field  Notes.   Microfilm, on file Department of Natural  Resources,
        Bureau of Surveys and Maps, Qlympia.


Kidd, Robert

  196^4  ^ synthesis of western Washington prehistory from  the   perspective
        ol  three occupation sites.  Unpublished Masters Thesis,  Department
        of Anthropology, University of Washington.


Lane, Barbara

  1973  Anthropological  Report  on  the  Identity,  Treaty   Status,   and
        Fisheries   of  the  Sti11aquamish  Indians.   Ms.  on   file,  U.S.
        Department of the interior and the Sti1laguamish Indian  Tribe.


Local Committee of Pioneers

  1906  An  Illustrated  History  of   Skagit   and   Snohomish   Counties.
        Interstate Publishing Co. Chicago.


Phillips, James W.

  1978  Washington   State  place  names.   l»th  printing.   University  of
        Washington Press, Seattle.


Stilson, M. Leland and James C» Chatters

  1981  Excavations  at  45-SN-A8N   and   45-SN-49A,   Snohomish   County,
        Washington.    University   of_   Washington,   Office   o_f   Pub! ic
        Archaeology. Reports _i_n Highway Archaeology 6.


Thomson, Jack

  1961  Preliminary Archaeological Survey of the Pllchuck River  and  South
        Fork of the Sti1laguamish River.  Washington Archaeologist, Vol. V,
        No. 3.
                                   258

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                                      15
U.S. Environmental protection Agency

  1983  Portions of preliminary DEIS,  Municipality of Metropolitan  Seattle,
        Sludge Management Plan, Region 10.


Whitfield, Un.

  1926  History of Snohomish County Washington,  Vol.  I.   pioneer  Historical
        Publishing Co., Seattle.
                                   259

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260

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	Appendix F
 Water Quality and Groundwater Data

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   Appendix F
Water Quality and
Groundwater Data
        261

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262

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        Table F-l.   North Fork of the Stillaguamish River
                       Water Quality Data1
parameter
Spec! -fie
conductance

ph

temperature
color

turbidity

di ssol ved
oxygen

nitrate !<
nitrite

ammonia


ammoni a

total
phosphorus


total
phosphorus

units

umhos

uni ts

degree C.
pi atinum
cobalt units
NTU


mg/1

mg/1
as M

mg/1
as N

mg/1
as NH4

mg/1
as P


mg/1
as ' J4
ft of samples

59

59

59

56
56


59


59


59


9


59



9
stati stic

mean
ma:: i mum
mi ni mum
max i mum
maxi mum
mean
max i mum
mean
maxi mum

mini mum
mean

mean
maximum

mean
max i mum

mean


mean
max i mum


mean
4 years data

62
97
6.6
8.4
17.8
36

10.4
120

9.8
11.6

.25
.62

.05
.48

.06


.03
.48


.07
dissolved Ortho
phosphorus

mg/1
as P

59

mean

. 003
dissolved Ortho
phosphorus

hardness
mg/1
as PD4
mg/1

33
25

mean
mean

.02
24. 2
non carbonate
hardness
di ssoved
calcium
dissolved
magnesium
di ssol ved
sodium
dissolved
potassium
bicarbonate
carbonate
al kal ini ty

carbon
dioxide
di ssol ved
sul -fate
dissolved
chloride
•fecal
mg/1
f
mg/1

mg/1

mg/1

mg/1
mg/1
mg/1
mg/1
as CaC03

mg/1

mg/1

mg/1

coliform2 no/ 100ml


25

25

25

25

25
26
25

26

26

24

25

4

mean

mean

mean

mean

mean
mean
mean

mean

mean

mean

mean

mean
ma;: i mum
2.8

6.5

1.9

1.9

.6
26.7

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                             Table F-2.    State  of  Washington  Water  Quality  Standards
                       n
                       O


AA
Ditraord inary



A
Excellent




D
Good





C
Fair



Lake Class




« ? "2
U D^O
4> 6 o
K O ">
Is s°
* 5 (10t>100)
U* J
3"
jj (10t>43)
•a a 100
£ g (10t>200)

? U0»>«3

*
ui «) 200
£ 9 (10l>400)

3 10°
H (10I>200)
"•-

|g 200
£ « iioiHOO)
fll
3

j. 50
3 <10l>100)
2
v
t
Si »* 4 •» i 9'5 <110 t-23/ff»5»

^7 n < i in
* /• U ^ Xiv . — . ._ . .
>8 0 <110 16
>8.0 <110 t.28/ov7)

>6 0 <110 l8
6'° U° t=12(T-2)

>fi 5 5 0 <110 19
(h) t- 16/T
*l^l

>5 0 « o oraturo shall not exceed values shown, duo in part to measurable (0.5*P)  increases resulting from humn  activities, nor shall  such temperature
    increases, <>t any cine, exceed thu (t)  values of the formula shown:  t - permissive increase; T • water temperature due to all causes combined.
(c)  Shall  rot U) within tlu I'OIKJO i>hown,  with ait induced variation of  loas than units fihrwn in parentheses.
(d)  •lite ruturjl turbidity conditions bhall  not bu oxoucded by noro titan tho valiu uhown.
(c)  Dissolved oxyijcn shall not exceed values shown, or 50 percent saturation, whichever is greater.
(f)  No muasurahlu ducruaao from natural conditions.
(•))  No iHMSurablo charwjo frun natural conditions.
(0)  Uiu:
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            Table F-3.  Stream Water Quality Standards
   Parameter                Units

Fecal Coliform


Dissolved
Oxygen

Temperature


pH



Turbidity                NTU
No./lOO ml.


mg/1


°C
  Statistic

Median
10 percentile

Minimum


Maximum
Increase

Maximum
Minimum
Variation

Increase
 Increase or variation due to human activities

NOTE:  < = Less than
       Standards from WAC 173-201

SOURCE:  Metro 1983d.
 Water
Quality
Standard

  <100
  <200

   8.0
  18
   0,
                                      8.5
                                      6.5
                                      0.5
                                  265

-------
                                   WATER-TABLE
                                   AQUIFER
                                           VASHON TILL
                          Monitoring W«!l
                          W«t«r L*v*l
                          Scr**n*d Intwva
                          Bottom of Holt
                          Approiimat* Direction
                          of Ground wit *r Flow
                          Geologic Conucl
                          (Darted wh*r* inferred)
                                                                    FIGURE
                                                                    Hydrogeologic Profile B - B'
       c
     SOUTH
                                                         C*
                                                       NORTH
   300
„ 200
 c
 o
 I
Ul
   100-
WELL
  2
                                                                            C/
                                                                        WIT^HER
                                                WATER TABLE
                                                AQUIFER  ^
        STILLAGUAMISH
        RIVER
                          VASHON TILL
EXPLANATION

   Monitoring Well
   W.t« L>v«l
   Scr»«n«d Interval
   Bottom of Hoi*
                                                                                     Approiimat* Direction
                                                                                     of CroundMt** Flow

                                                                                     Gcologk Contact
                                                                                     (Dathod wh«re inUrradl

                                                                                     Water-Tab)*
                                                                         FIGURE  F-l
                                                                         Hydrogeoiogic Profile C — C'

                                                                         SOURCE:  Metro  1982a.
                                           266

-------
         Table F-4.   Pilchuck  Tree  Farm Spring Water Analysis
                   (Sampled March, May,  June,  July  1982)
   Conventional
    Parameters
  NH -N
  NCT+NO -N
  Total P
  Total K
  pH
  Turbidity
  Conductivity

Metals
  Cadmium
  Chromium
  Copper
  Mercury
  Nickel
  Lead
  Zinc

Bacteria  (Geometric Means)
  Total Coliform
  Fecal Coliform
  Fecal Streptococci
Viruses  - Not analyzed

Parasites - Not detected in 2  samples tested

Chlorinated Organics - Not detected in 2 samples  tested


Unit
mg/1
mg/1
mg/1
mg/1



mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
MPN/100 ml
MPN/100 ml
MPN/100 ml
Bluff
Mean
(n = 7)
.019
1.46
.16
1.15
7.1
3.8
96
<.0001
<.024
<.007
<.0002
.026
<.029
<.006
113
4
74
Springs

Minimum
.003
0.33
.03
<.77
6.7
0.6
82
<.0001
<.02
<.001
<.0002
.02
<.02
<.006
8
<2
17


Maximum
.05
2.64
.51
1.66
7.6
8.2
110
.00014
.03
.02
.0005
.03
.04
.013
700
17
490
NOTE:   Yersinia was isolated  from one sample.

       MPN = Most Probable Number
       <   = Less than
SOURCE:   Metro  1983d.
                                        267

-------
                                    Table F-5.   Preproject Groundwater Quality Data -
                                                    Pilchuck Tree Farm
IIEE fUO( - MSlUtt 6SOUHWWI SAWUK
Ct»r«ll lOKAl. eWnlfJUS
tMOJUBt-lt It^'l)
Illfilt « 119/11
r'XAtphorvs Itg/ll
Pol MM o« 115/11
|H

CwJutliiKt mikcii
«ms
Arseatc l«9/l 1
kiriii (tq/ll
Cdlini Ii9'll
Chrtuiiu li;/ll
tofitr 119/11
NJ If0» l.,.'ll
01 lud Itq/ll
00 Jtercor, (19/11
Hiclfl ii;/ll
Sfiftiat 119/11
Sll'tr 119/11
IlH 119/11

IACIEMA

lotil calilort II ptr |M
•II
fKi\ col i loft II ier 100
•II
FKJ| slftpl. II per IM
• II
StliMtllj II let IM •!>
Iff'-liil II ptt IM III

Was -. !5'.j!.!l-=c.!»
91!)

PMISI1ES

IMCMIC TOUCUIS

I.I. - tot l>t«l«<
I.I. - lot inilT.it
(•fill VAIVJlliklfl

SltllM 1 • FiTKM'S itLl
SMFtE MIE MO SMPU nm»:
UIMIKt MIEI 1/30/12 11/31/12 12/11/12
SI4MSHS IEMI 15331 • KniCIIE 15512 15731
.Mil
10.0 •;/! .12
.0115
— .'!
4.5
1.5
5«

0.05 19/1 (.Ml
1.0 t;/l .17
0.01 H'l (.00»l
0.03 <9/l .Mil
.11
.12
0.05 •;/! .(431
O.M3 15/1 <.K*3
.Mil
O.CI 19/1 (-OM3
Q.n >;/! (.0«4I
.1




•2 iff l« >l (3

'3 iff |i>» •) '3

... t
'.]
<1

_
(2

I.I.

I.I.

.0031 (
.12
.032
.15
1.5
1.1
51

(.Ml
.15
(.0*1
.MI5
.11
.li
.M75
(.0043
.13
(.OM3
(.00«l
.054



















.Ml
.11
.127
M
4.7
.1
51

U
HA
U
U
M
M
U
M
•1
M
M
U




(2

(J

4/ll
Cocpff (19/1 1
IrCfl If9/ll
ui< in'ii
VU.f. (19/11
Iliclel 119/11
Stlroui l»4/ll
SMm (19/11
!<>( li;/ll

KCIEIII

hill colllvi II IN IM
til
Fr«l tohlvi II iff IM
III
• rttl llftpt. II iff IM
• II
SiliontlU II |ff IM ill
Inlitii II irr IM ill

HH.1 - lolil II ptr IM
9'•.
O.M2 q/l (.OM3
.02
0.01 19/1 <.0t»l7
0.05 K'l •*»•
(.««*




<3 IH w il 7< i;

'2 Iff IM II (7 <3

240
(1
— 1 1


< j

I.I.

I.I.

•mill •) IW kxlffli lt«li«9 km kfw liitiitr*
MltwHMl tuff4f4 n't lnnli«9 iittr lUMirlt.
CHinlftliwt it* ilw k» fi|«lel, ii'lK.liilr •
11/21/12

(.Ml
1.2
.011
U
4.4
.M
117

M
IK
M
H
U
u
u
•a
M
W
1*
U




1

>2

1
M



M

M

M

u l irfviwl
Fl.tUltiwl
ki* Ikf tlfitnt
12/11/12
15755

(.Ml
1.51
.031
1.55
5.7
1.2
113

(.M3
.M
.0«',l
(.Ml
.00?!
U
(.0*1
.W*3
.0011
(,OC1
«.WI
.«31




M!

>2

41
m
•*


M

1*

M

•MO. lo ckfiittl
u %ilrtf«t coMtBl
It (ftlWll Mil
i/i/ei
15740

.012
1.41
.024
1.52
7.5
1.5
111

(.M;
.15
•
.Mil
.li:
M
.Ml!
.ftid-l
.W
'.«!
'.«.«•!
•




5

v3

^
, 1
1


. ^

1

1




                                                                                     Ut hiilt ol

-------
                                                                                                            Table  P-5.    Cont'd.
                          TREE FA«H  - BASELINE 6ROUNMATER SAKPLING
                          STATION C  - KlISCHER'S Kil
                                                                                                                                                                IDEE FAfin - IASELINE GRO'JNDVATEB SAHPLIN6
                                                                                                                                                                STATION D - LINDAL/ESPERSON VEIL
 CONVENTIONAL CHEH1CALS
Aiioniul-N fig/11
Nitrltr-N ito.'ll
Phosphorus liq/11
Potassiul ttg/1!
pN
Turbidity IKTU)
Conductivity  (Sinos)

HETAL5
                          MINCING HATER
                          STANDARDS (EPA)
                          10.0 15/1


t\J
CT\
kO







Arsenic lia/ll
Biriu> !i;/l)
Cijiiui dq/ll
Chruiuo li^.-'l )
Ccpper dg/1)
Iron li;/l)
\.eti lig.'ll
Ncrcvjry l.:/ll
Nickel Ii9/ll
Seleniuc (iq/ll
Silver Icc/l)
Jirc '»;.'l!
0.05 15/1
1.0 cs/1
0.0! £3/1
0.05 «3/l
...
—
0.05 tg/l
0.00: ag'l
—
0.0! 15/1
0.05 to..'!
—
                                               SAflPLE  DATE AND SAnPLE NIUIBER:
                                           J/20/82          9/27/82
                                               15531         15515
                                                             IColilon only)

                                               .0038
                                                1.96
                                               .005?
                                                 .3?
                                                 6.2
                                                 5.7
                                                 194
                                               (.003
                                                 .21
                                              (.0001
                                               (.00!
                                                 .05
                                                (.03
                                                .024
                                              (.0002
                                                 .02
                                               .0004
                                              (.0001
                                                .0:4
W.CTEMA

Total  C3lilon  II per 100
•1)                       <2 ser 100 ill
Fecal  colllnn  !l ftr 100
tl)                       <: per !M el
Fe:al  strept.  !l per  100
ill
Salunilla II oer  !M> itH  —
Verii.iia f!  per IK' *!!

VlfiL'S - Total  II per  100
PARASITES

ORGANIC TOIICANTS
                                                  II

                                                  <3


                                                  (2

                                                 N.D.

                                                 H.O.
11/29/82
15594
(.001
4.09
.0097
NA
5.9
.05
69
12/13/82
15594
.002
6.3
.01
.92
6
.45
120
I/3/J3
15761
.002
4.17
.017
.88
7.7
100

CONVENTIONAL CHEMICALS
AtioniuE-N (tg/ll
Nitrate-* lig/l)
Phosphorus (19/11
Potassiui (15/1)
pH
Turbidity INTUI
Conductivity (Hihos)
DRINKING HATER
STANDARDS IEPAI
10.0 tg/l
	
...
—
1/20/82
15532
.0031
1.78
.0021
.3
6.B
4.5
60
DATE AND SAMPLE NUMBER:
11/19/82
15595
(.001
1.51
NA
5.9
.25
55
12/IJ/B2
15757
(.001
3.72
.01]
.75
S.B
.47
60
I/3/B3
15762
.0069
4.42
.0006
.86
7.5
.6
65
17
(2 '



22
(2
(2
NA
NA
13
(2
<2
NA
NA
2
(2
(2
(3
i
NA

NA
N.D. - Not detected        Results ol the bacteria teiing have been discussed in a previous  teio. Ho cheaical
N.A. - Not analvied        leasureient eiceeded  sale drinkinq. niter standards.  Fluctuations  in nutrient content
                           are not unusual and pose no health concerns.  Occasional changes in trace eleient
Hdata unavailable)         concentrations lay also be  espected,  particularly unen the eleient  is present near
                           the liiits ol detection.
                                                                                                                                      NETALS
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
(.002
.12
(.0001
(.001
,073
NA
.0017
(.0002
.0027
<.OC1
(.0001
.015
(.002
i j
l
.002
.22
NA
.0015
.0002
.0049
(.001
<.ODOI
i
Arjtnic (ig/ll
Bdriui (113/11
Cidiiui (19/1!
Chrofiiun (cg/1)
Copper lag/1)
Iron («5/ll
Lead l>g/ll
(tercury ieq/ll
Nickel '.'9/11
Sc-leniue (ig/1)
Silver lag/11
line !:;.'! )

0.05 ig/1
1.0 tg/l
0.01 09/1
0.05 ig/1
—
0.05 og/1
0.002 ig.'l
0.01 ig/1
0.05 =g/l

(.003
.07
(.0001
(.001
.0057
(.03 '
.0026'
(.0002
.0012
(.00017
(.000!
.036
NA
NA
NA
• NA
NA
«A
NA
N*
NA
UA
NA
HA
(.002
.07
.00023
<.001
.0053
NA
.05i
(.0002
(.001
(.001
(.OC'Ol
.043
(.002
.06
»
.0023
.024
NA
.0019
(.(•002
.016
(.00!
.0002
t
                                                                                                                                       PftCIERIfi

                                                                                                                                       Total colifort II per  100
                                                                                                                                       cl)                       (2 per 100 tl
                                                                                                                                       Feci! coiitcn II fir  100
                                                                                                                                       tl!                       '2 per 100 a!
                                                                                                                                       Fecil Btreot. II per IOC
                                                                                                                                       ill
                                                                                                                                       Siltcnella (I per 100  >1)  —
                                                                                                                                       Versinia  II per  100 »!)

                                                                                                                                       VIRUS - Total (I per 100
                                                                                                                                       PARASITES
                                                                                  (2
                                                                                  <3
                                                                                  (3
                                                                                                                                       ORGANIC TD1ICANIS

                                                                                                                                       N.D.  - Not detected
                                                                                                                                       N.A.  - Not anilyled

                                                                                                                                       ddata unavailable)
                                                                                                                                                                                      N.D.
NA
NA
NA

NA

NA
                 <2
                 NA
NA

NA

NA
                                                                                                                                                                Results ol the bacterU testing have been discussed in a previous icto. No cheiic
                                                                                                                                                                •easureient eiteeded  sale drinking nattr  slindjrds.  Fluctuitigns in nutrient con
                                                                                                                                                                are not unusual ard  pose no health concerns.  Occasional cninoes in trace e!e«ent
                                                                                                                                                                concentrations lay also be expected,  particularly nhen the eleient is present nea
                                                                                                                                                                the liiits ol detection.
SOURCE:    Metro  unpublished  data.

-------
 Table F-6.  Minimum Acceptable Water  Supply Quality'
     Parameter
Total Coliform
 Statistic

Monthly mean
Maximum
  Limit
<2/100 ml
4/100 ml
Arsenic

Barium

Cadmium

Chromium

Lead

Mercury

Nitrate  (as N)

Selenium

Silver
Maximum

Maximum

Maximum

Maximum

Maximum

Maximum

b


Maximum

Maximum
0.05 ng/1

1.0 mg/1

0.01 mg/1

0.05 mg/1

0.05 mg/1

0.002 mg/1

10.0 mg/lb

0.01 mg/1

0.05 mg/1
Endrin                        Maximum

Lindane                       Maximum

Methoxychlor                  Maximum

Toxaphene                     Maximum

2,4 - D                       Maximum

2,4,5 - TP  (Silvex)           Maximum
               0.0002 mg/1

               0.004 mg/1

               0.1 mg/1

               0.005 mg/1

               0.1 mg/1

               0.01 mg/1
 Values are Primary Drinking Water Standards as defined
 by the Environmental Protection Agency.

 The 12-month moving geometric mean shall not exceed
 5 mg/1 and the maximum monthly average for November,
 December, and January shall not exceed 10 mg/1.

SOURCE:  Metro 1983d.
                             270

-------
	Appendix G
 EPA Criteria for Classification of Solid Waste Disposal
              Facilities and Practices (40 CFR Part 257)

-------
                    Appendix G
  EPA Criteria for Classification of Solid Waste
Disposal Facilities and Practices (40 CFR Part 257)
                          271

-------
272

-------
  Thursday
  September 13, 1979
  Part IX



  Environmental

  Protection  Agency

  Criteria for Classification of Solid Waste
  Disposal Facilities and Practices; Final,
  Interim Final, and Proposed Regulations (as
  corrected in the Federal Register of
  September 21, 1979)
273

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53438     Federal Register  / Vol. 44, No. 179  / Thursday. September 13, 1979 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 257
[Docket No. 4004; FRL 1234-1]
Criteria for Classification of Solid
Waste Disposal Facilities and
Practices
AGENCY: Environmental Protection
Agency.
ACTION: Final rule and interim rule.

SUMMARY: This regulation contains
minimum criteria for determining what
solid waste disposal facilities and
practices pose a reasonable probability
of adverse effects on health or the
 environment. Those facilities that
 violate the criteria are "open dumps" for
 purposes of the State Solid Waste
 Management  planning effort supported
 by EPA under Subtitle D of the Resource
 Conservation and Recovery Act  (RCRA
 or the Act). The criteria also provide the
 standard to be applied by the Federal
 district courts in determining whether
 parties have engaged in acts that violate
 the prohibition of open dumping, also
 contained in Subtitle D of RCRA, The
 criteria also partially fulfill the
 requirement of Section 405 of the Clean
 Water Act (CWA) to provide guidelines
 for the disposal and utilization of
 wastewater treatment plant sludge. Any.
 owner or operator of a publicly owned
 treatment works must comply with these
 criteria when disposing of sludge on the
 land.
 EFFECTIVE DATE: October 15.1979.
DATE: For purposes of the Interim Final
 portions of the criteria [sections 257.3-5
 and 257.3-6(b)|. public comments will be
 accepted until November 20. 1979.
 ADDRESS: Submit comments to: Mr.
Emery Lazar. Docket 4004.1, Office of
Solid  Waste (WH-564), EPA.
Washington. D.C. 20400.
 FOR FURTHER  INFORMATION CONTACT:
 Mr. Truett V.  DeCeare. Jr..  P.E., Office of
 Solid Waste (WH-563). U.S.
 Environmental Protection Agency. 401 M
 Street. S.W.. Washington. D.C. 204GO.
 Telephone (202) 755-9120.
 SUPPLEMENTARY INFORMATION:
 I. Authority
   This regulation is issued  under
authority of Sections 1008(a)(3) and
4004(a) of the Solid Waste Disposal Act.
as amended by the Resource
Conservation and Recovery Act of 1976,
42 U.S.C.  6907(a)(3) and G944(a), as well
as Section 405(d) of the Clean Water
Act. as amended. 42 U.S.C. 345.
II. Background
   This regulation was published  in the
Federal Register in proposed form for
public review and comment on February
6. 1978. The Agency held five public
hearings and eleven public meetings to
discuss the proposed regulation and
received a substantial number of written
comments on the proposal. Having
considered the views of the public, the
Agency is now promulgating this
regulation in final form. This preamble
discusses some of the more significant
Issues raised during the public comment
period and revisions made on the basis
of those comments.
  The objectives of  the Act are to
promote the protection of health and the
environment and to  conserve valuable
material and energy resources.  In order
to accomplish this, the Act sets forth a
national program to improve solid waste
management. Including control  of
hazardous wastes, resource
conservation, resource recovery, and
establishment of environmentally sound
solid waste disposal practices.  This is to
be carried out through a cooperative
effort among Federal, Slate, and.
substate governments and private
enterprise.
  Subtitle D of the Act fosters this
cooperative effort by providing for the
development of State and regional solid
waste management  plans that involve
all three levels of government. As the
Federal partner in this process. EPA
seeks, through regulations and financial
assistance, to aid State initiatives in the
formulation and implementation of such
plans.
 • Section 4002(b) of the Act requires the
Administrator to promulgate Guidelines
for the Development and
Implementation of State Solid Waste
Management Plans.  On July 31,1979,
EPA issued those guidelines (44 FR
45066). While those  guidelines are to
consider a broad range of topics. Section
4003 of the Act identifies the minimum
requirements which State plans must
address. EPA provides financial
assistance to help the States develop
and implement their plans. Under
Section 4007. EPA reviews and  approves
Stale plans which satisfy the  minimum
requirements of Section 4003.
  The Slate solrd waste management
plan is the centerpiece of the Subtitle D
program. Through the plan the State
identifies a general strategy for
protecting public health and the.
environment from adverse effects
associated with solid waste disposal, for
encouraging resource recovery and
resource conservation, for providing
adequate disposal capacity in the State,
and for dealing with other issues
relevant to solid waste management.
The plan must also set forth the
institutional arrangements that  the State
will use to implement this strategy. (A
more detailed description  of the
planning program is  contained in the
Preamble accompanying the Section
4002(b) guidelines.)
A. Section 4004: Disposal Facility
Criteria
  Under section 4004(a) of the Act the
Administrator is to promulgate
"regulations containing criteria for
determining which facilities shall be
classified as sanitary landfills and
which shall be classified as open dumps
	The criteria establish the level of
protection necessary to provide that "no
reasonable probability of  adverse
effects on health or the environment"
will result from operation  of the facility.
In setting these criteria EPA is providing
a general definition of "sanitary landfill"
and "open dump". As part of their
planning programs, the States will
evaluate existing disposal facilities to
determine whether they comply with the
Section 4004 criteria. Those facilities
which do not satisfy the criteria are
"open dumps" under the Act. EPA will,
under authority of Section 4005(b).
publish a list of open dumps in the
Federal Register.
  The inventory of "open  dumps" will
serve two major functions. First it will
inform the Congress and the public
about the extent of the problem
presented by disposal facilities which
do not adequately protect public health
and the environment. Second, it will
provide an agenda for action by
identifying a set of problem facilities.
routinely used for disposal, which
should be addressed by State solid
waste management plans  in accordance
with Section 4003 of the Act
  Essentially, the inventory is a
•planning tool which  supports the Slate
planning effort. The States must know
where the problem facilities are in order
to satisfy Section 4003(3) which requires
that the plan "provide for  the closing or
upgrading of all existing open dumps
within the Slates
B. Section 1003(c)(3): Open Dumping
Criteria
  Under Section 1008(a)(3) of the Act
the Administrator is  to publish
suggested guidelines that provide
minimum criteria "to define those solid
waste management practices which
constitute the open dumping of solid
waste or hazardous waste." Thus, these
criteria arc to establish a broad
definition of the act of open dumping.
which is prohibited under  Section
4005(c) of the Act.
  The prohibition may be  enforced in
Federal district court through the citizen
suit provision in Section 7002. The Act
docs not give EPA authority to take legal
action against parties that may violate
the open dumping prohibition. The
application of the open dumping criteria
to the specific acts of specific
                                                           274

-------
          Federal  Register / Vol.  44, No. 179  /  Thursday,  September  13,  1979 / Rules and  Regulations   53439
 individuals is a matter for the Federal
 courts to determine in the context of
 particular cases. Judicial review of
 specific acts in the context of open
 dumping suits should not be confused
 with State planning activities,
 particularly the evaluation of disposal
 facilities for the inventory of open
 dumps. The inclusion of a facility in the
 list of open dumps is not an
 administrative determination by EPA
 that any particular parties are engaging
 in prohibited acts of open dumping. (The
 Preamble accompanying  the Guidelines
 for Development and Implementation of
 State Solid Waste Management Plans '
 (44 FR 45066) provides a more detailed
 explanation of this issue.)
 C. Section 405(d): Sludge Disposal
 Guidelines
    Under Section 405(d) of the Clean
 Water Act EPA issues guidelines for the
 disposal and utilization of sludge. Under
 Section 405(e) of the CWA owners and
 operators of publicly owned treatment
 works (POTW's) must dispose of
 sludges from such works in accordance
 with those guidelines. Criteria designed
 to avoid a reasonable probability of
 adverse effects on health or the
 environment from disposal of sludge on
 land are clearly within the scope of this
 provision of the CWA.
 D. Copromulgation of the Criteria
    The criteria which EPA promulgates
' today are designed to fulfill or partially
 fulfill the requirements of each of the
 provisions discussed above. While all
 three provisions embody different
 implementation schemes, they all are
 concerned with the adverse effects on
 health or the environment that may be
 caused by solid waste disposal
 activities. Since there is an inherent
 compatibility of purpose among the
 three provisions, EPA has decided to
 juncture the criteria so they may be
 used in  all three contexts. EPA believes
 that co-promulgation of regulations,
 where possible, improves the quality of
 its regulatory efforts by eliminating the
 potential for inconsistencies among
 similar regulations and by providing a
 clear statement to the regulated
 community of the standards to which
 they will be held.
   As an example of the compatibility
 between provisions, the facility
 classification criteria for purposes of the
 State planning program can, and
 probably should, be concerned with the
 same set of environmental effects as.the
 criteria defining the prohibited act of
.open dumping. Regardless of whether
 one is evaluating facilities to aid in the
 establishment of setting state  planning
 priorities or examining the acts of
specific individuals to determine legal
liability for open dumping, the same set
of environmental effects should be of
concern. At the same time, having a
single set of criteria for defining
unacceptable environmental effects
does not undermine the use of that
definition for different purposes.
   It should be pointed out that these
criteria are not necessarily the only
guidelines to be promulgated under
Section 405(d) of the CWA. These
criteria apply where the owners and
operators of POTW engage in the
placement of sludge on the land. Future
EPA guidelines on sludge disposal and
.utilization may address incineration,
energy recovery, and give-away or  sale
of processed sludge.  •
III. General Approach
   This regulation sets forth eight criteria
that address broad classes of health and
environmental effects that may be
caused by solid waste disposal
'activities. The criteria are structured to
define unacceptable impacts, those that
present a "reasonable probability of
adverse effects on health or the
environment" In terms of the three
•statutory provisions authorizing this
regulation, the criteria define an open
dump (RCRA Section 4004), the
minimum elements of prohibited open
dumping practices (RCRA Section
1006(a)(3)) and the effects which must
be avoided by POTW owners and
operators (CWA Section 405).
   EPA recognizes that these  criteria will
be applied to a variety of situations and
that there is a need for flexibility in the
•standards to allow them to be applied to
particular circumstances. During the ••••
comment period some reviewers . •' ::
expressed preference for greater
specificity in the criteria, including more
detailed design and operating   ..  -•
requirements. Others favored greater
flexibility and opportunity for
consideration of local, site-specific
conditions.
  In developing the final criteria the
Agency attempted to be as specific  as
possible without reducing the
opportunity for State and local solid
waste management and enforcement
agencies to take into account the site-
by-site variations and make
assessments based on local conditions.
Wherever possible EPA tried to set
specific performance standards tha>
define unacceptable environmental
effects. Such an approach should
provide a concise  and measurable
means of determining compliance with
the criteria. However, in some situations
it was not possible to devise  a
meaningful performance standard for
the environmental effect of concern,
 given the lack of experience with such
 an approach to regulation of solid
 waste.
   Where specific performance
 standards were not possible, EPA
 specified an operational technique to
 achieve the desired level of protection.
 When that approach was necessary the
 criteria maintain regulatory flexibility
 by allowing for the use of alternative
 techniques that  achieve the same'
 general performance level. Parties
 claiming that alternative approaches  '
 provide protection equivalent to that of
 methods described in the criteria have
 the burden of establishing that fact.
   In addition EPA wishes to emphasize
 that the standards established in the
 criteria constitute minimum
 requirements. These criteria do not pre-
 empt other State and. Federal
 requirements. Nothing in the Act or the
 CWA precludes the imposition of
 additional obligations'under authority of
 other laws on parties engaged in splid
 waste disposal.      ••
   Various commenters criticized EPA's
 general approach as being either too
 restrictive or too lenient. Some argued
 that implementation of the criteria
 would substantially reduce needed
 disposal capacity. The Agency
 recognizes that one of  the most critical
 problems in the solid waste       - • '
 management field today is  the lack of'
 acceptable disposal facilities due, in
 part, to public opposition to their siting.
 However, this particular rulemaking
 cannot deal directly with this problem.
   The Agency is committed to
 evaluating other means by which it can
" help with the problem. Adequate
• disposal capacity is essential
Nationwide. Hopefully, imple'mentau'on
 of the criteria will increase the
 credibility of disposal operations,
 thereby aiding in reducing public
 opposition to acceptable and needed
 facilities.
   Some commenters felt that the criteria
 should be written very stringently in
 order to.provide an incentive for
 initiation of resource recovery and
 conservation practices. Other
 commenters observed  that, even with
 increased levels of resource recovery
 and conservation, disposal facilities
 would continue to be required into the
 foreseeable future; even resource
 recovery facilities produce a residue
 which requires disposal. The Agency
. believes that resource recovery and
 conservation  are desirable  solid waste
 management approaches which should
be actively pursued. However, the
purpose of the criteria  is to define
 disposal activities which pose no
reasonable probability of adverse
effects on health or the environment.
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 and the criteria have been developed
 with thai goal in mind. While the
 Implementation of these criteria may
 make resource conservation and
 recovery more economically
 competitive, these regulations have not
 been formulated simply to advance that
 cause.  Such an approach is not
 authorized by the Act.
   EPA also received comments
 attacking the Agency's use of standards,-
 definitions and approaches developed
 under other Federal environmental and
 public  health programs. They claimed
 that incorporating these items into the
^criteria extends those other programs
 beyond their statutory authority. While
 the use of particular Federal standards
 will be discussed  later in this Preamble
 in the context of each criterion, a
 general point should be made about the
 use of  approaches developed or
 employed in other programs. The Act
 requires that the criteria address
 adverse health and  environmental
 .effects of solid waste disposal, whatever
 those might be. The use of other Federal
 Standards in responding to this broad
 mandate is. in  fact, quite desirable in
 order to minimize duplicative,
 overlapping and conflicting policies and
 programs. Unless  it  can be shown that
 other Federal standards and approaches
 are clearly inconsistent with the Act's
 objectives, it is within the Agency's
 discretion to use them, where
 applicable, in writing RCRA regulations.

 IV. The Criteria

 A. Scope

   These criteria apply to the full range
 of facilities and practices for "disposal"
 of "solid waste", as  those terms are
 defined in Section 1004 of the Act.
 Various commenters suggested the
 exclusion or inclusion of specific types
 jf solid waste disposal activities. EPA
 .•xamined these suggestions in light of
 the Act's definitions. Section 1006 of the
 Act (which directs the Agency to avoid
 duplicative regulatory programs), the
 Act's legislative history and the
 objectives of Subtitle D. EPA has
 concluded that the criteria apply to all
tolid waste disposal with the following
 exceptions:
   1. The criteria do not apply to
 agricultural wastes, including manures
 and crop residues, returned to the soil as
fertilizers or soil conditioners. All other
disposal of agricultural wastes,
including placement  in a landfill or
surface  impoundment, is subject to these
criteria. This exclusion is based on the
House Report (H.R. Rep. No. 94-1491,  '
94th Cong., 2nd  Sess. 2(1976)) which
explicitly indicates that agricultural
                               wastes returned to the soil are not to be
                               subject to the Act.
                                 2. The criteria do not, at this time,
                               apply to overburden from mining
                               operations intended for return to the
                               mine site. The House Report indicates
                               that this type of overburden is not to be
                               the immediate focus of the Act's
                               programs.
                                 3. The criteria do not apply to
                               domestic sewage or treated domestic  \
                               sewage. However, the criteria do apply
                               to disposal of sludge resulting from the
                               treatment of domestic sewage. In
                               defining "solid waste" the Act
                               specifically excludes solid or dissolved
                               material in domestic sewage. Treated
                               domestic sewage from which pollutants
                               have been removed in a wastewater
                               treatment plant is still considered to be
                               domestic sewage for purposes of the
                               Act. Including such wastewater
                              . effluents within the Act's  scope is
                               particularly unnecessary because
                               existing EPA programs concerning
                               treatment of domestic sewage are
                               seeking to assure that these effluents are
                               disposed of in an environmentally sound
                               manner.
                                 However, during the treatment of
                               domestic sewage, solid and dissolved
                               materials are removed from the sewage
                               and collected as sludges. Typically,
                               these sludges are disposed of separately
                               from the treated sewage which passes
                               through the treatment plant. The
                               language of Sections 1004(27) and
                               1004(26A) indicate that sludge generated
                               by a wastewater treatment plant, water
                               supply treatment plant or air pollution
                               control facility is solid waste for
                               purposes of the Act. EPA believes that
                               while the Congress intended to exempt
                               treated sewage effluents from the Act's
                               provisions, it intended to include
                               sludges created by the operation of
                               treatment facilities. This approach is
                               consistent with Congressional intent,
                               expressed in  Section 1002(b)(3) and the
                               legislative history, that the Act
                               specifically address the new solid waste
                               management  problem that resulted from
                               effective implementation of programs
                               designed to protect the air, water and
                               other environmental resources.
                                With this interpretation a question is
                              raised  about the operation of septic
                              tanks, a particular type of sewage
                              treatment device. The materials which
                              pass through the tank and are released
                              into drainage fields are analogous to the
                              treated sewage effluent passing through
                              a treatment plant, and thus are not
                              considered solid waste. The materials
                              which settle to the bottom of the septic
                              tank and are subsequently removed for
                              disposal at some other facility are
                              analogous to the sludge created by the
                              operation of other sewage treatment
 processes. Therefore, septic tank
 pumpings fall within the Act's definition
 of solid waste.
   4. The criteria do not apply to solid or
 dissolved materials  in irrigation return
 flows. This exemption is clearly stated
 In Section 1004(27) of .the Act.
  .5. The criteria do not apply to source,
 special nuclear, or byproduct material
 as defined by the Atomic Energy Act of
 1954. as amended (68 Slat. 923). This
 exemption is stated  in Section 1004(27)
 of the Act.
   6. The criteria do not apply to
 industrial discharges which are point
• sources subject to permits  under Section
 402 of the Clean Water Act as amended
 In defining solid waste the Act
 specifically exempts these discharges.
 The principal purpose of this provision
 is to assure that waters of  the United
 States (the jurisdicnonal concern of the
 Clean Water Act) are not regulated
 under this Act.
   7. The criteria do not apply to
 facilities for the disposal of hazardous-.
 wastes subject to Subtitle C of the Act
 Section 3004 establishes the standards
 which will be applicable to such     .-
 facilities. EPA's final regulations for its
 hazardous waste program will delineate
 the class of facilities subject to  the
 Subtitle C requirements.
   8. The criteria do not apply to disposal
 df solid waste by underground well
 injection that is subject to regulations
 (40 CFR Part 146) for the Underground
 Injection Control Program (UICP) under
 the Safe Drinking Water Act, as
 amended 42 U.S.C 3001. et seq. While
 the subsurface emplacement of fluids
 through a well (the activity,regulated by
 UICP) could also fall wilhin the Act's
broad definition of disposal. Section
1006 of the Act requires that EPA avoid
duplication with its other programs
(including those under the Safe  Drinking
Water Act) in administering the Act.
Leaving regulation of underground well
injection to the UICP is consistent with
that mandate and is especially
appropriate since the UICP seeks to
achieve objectives similar to those of
the Act.
B. Definitions (Sectioi\2S73)
  General definitions .which apply to all
the criteria are presented in § 257.2, The
section defines "disposal,"  "facility."
"leachate," "open dump," "practice."
"sanitary landfill." "sludge," "solid
waste." and "state." Also definitions
that are only applicable to a-particular
criteria are presented m that criteria
section.
  EPA received many comments that
reflected a concern over the definition of
"facility". Several commenters
suggested that EPA exempt  such things
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 as wastewater treatment lagoons,
 potable water treatment lagoons,
 surface impoundments (pits, ponds,
 lagoons, basins], mining waste disposal
 facilities, utility waste disposal facilities
 and agricultural waste disposal
 facilities. The Act does  not define the
 term "facility". EPA believes that the
 term should be interpreted broadly
 unless such an interpretation clearly
 conflicts with other provisions or
 objectives of the Act.
   After examining  these requests for
 exemptions in light of the Act and its
 legislative history, EPA concluded that
 there was no statutory basis for
 excluding these types of facilities. All
 such facilities could present a
 reasonable probability of adverse
 effects on health or the  environment.
 EPA does not have any basis for
 determining that such facilities are not
 "solid waste disposal facilities" for
 purposes of the Act.
   Several commenters asked whether
 the definition of "facility" would
 encompass "backyard" disposal
 practices such as home compost piles or
 burning of household wastes. EPA does
 not believe that Congress intended the
 Subtitle D  classification scheme to be
 implemented at the household level.
 Section 1004(27) refers to wastes from
 "community activities". In addition, the
 legislative history indicates at several
 points that "municipal" wastes are of
 concern under Subtitle D. The Act's
 emphasis on "community" or
 "municipal" waste, indicates that the
 Congress intended  to focus on solid
 waste managment at  that level rather
 than at the household level. EPA
 believes that "backyard" practices
 should be controlled through State or
 local nuisance and  public health laws.
   Some commenters suggested that
 disposal facilities used by small
 communities (especially small facilities
 in rural areas] be excluded from
 coverage due to the anticipated higher
 unit cost (cost per capita or cost per ton
 of waste) of compliance for such
 facilities. The Agency found no basis for
 such an exclusion. In  fact, such an
 exclusion could foster the development
 of additional small  facilities, in order to
 escape the cost of compliance and, *
 cumulatively, could result in greater
 environmental damage in rural areas.
 Thus, the criteria apply  to large and
 small facilities, whether urban or rural,
 because it is essential that all facilities
 prevent adverse impacts on health and
 the environment in  accordance with the
 criteria.
  Less sophisticated and less costly
design and operational techniques,
however, may be applicable at smaller
facilities due to the  smaller quantities of
waste disposed and reduced magnitude
of potential adverse effects. In addition,
small or rural communities may take
various approaches to reduce the per
capita cost burden and achieve
economy of scale through regionalized
collection and disposal systems, sharing
of equipment among facilities, or
operation of facilities only during
limited  hours.
  During the public comment period it
was suggested that there be less
stringent criteria for existing facilities
than for new facilities. In considering
this suggestion the Agency has found no
difference in the potential adverse
effects from existing as opposed to new,
facilities. With regard to implementation
of the criteria, however, the Act does
recognize the need to continue the
controlled use of existing facilities while
alternatives which comply with the
criteria are being developed. In taking
steps to close or upgrade existing open
dumps, a State may issue compliance
schedules that allow use of a disposal
facility while it is being upgraded or
while alternative disposal options are
being developed.
  A few commenters also raised the
question of whether a junk yard, which
may buy or sell waste items, is a solid
waste disposal facility. While a junk
yard is  clearly a "solid waste
management" facility under the Act,
•there is some question whether the
operation of a junk yard constitutes the
disposal of solid waste.
  Under Section 1004(3) "disposal"
involves the placement of solid waste
into or on any land or water so that a
constituent of the waste may enter the
environment. This entry of.waste
materials into the environment is an
essential component of the Act's
definition. As the Senate Report states,.
"Disposal is letting wastes out of
control" (Sen. Kept. No. 94-988. 94th
Cong., 2d Sess. 26 (1976)).
  If a junk yard is operated in such a
way that no waste material enters the
environment  then it is possible that it is
not a solid waste disposal facility. If
constituents of the waste, however, are '
entering the environment (e.g. battery   _
acids from automobiles leaching into the
ground), then the junk yard would be a
disposal facility. It is up to the State to
determine whether particular junk yard
operations constitute disposal of solid
waste.

C. Reorganization of the Criteria
  After  reviewing the comments EPA
has decided to change the format of two
portions of the criteria as they appeared
in the proposed regulation. The criteria
concerning environmentally sensitive
areas and disease have been
reorganized.
  The proposed regulation had one
section that addressed the location of
disposal facilities in wetlands,
floodplains, permafrost areas, critical.
habitats of endangered species, and
recharge zones of sole source aquifers,
all of which were categorized as
"environmentally sensitive areas". In
the Preamble to the proposed regulation
the Agency also requested comment on
other areas, specifically karst terrain
and active fault zones, for similar
consideration.      "           ,
  Environmentally sensitive areas are  '
no longer addressed in a separate
section. Criteria regarding floodplains.
and critical habitats of endangered
species appear in independent sections
discussed later. Wetlands-are addressed
in the section on surface water, since
wetlands are treated in the same
manner as surface waters under the
Clean Water Act. Concerns for recharge
zones of sole source aquifers are
directly related to those for ground-   -.
water protection; thus, protection of sole
source aquifers-has been incorporated  :
into the ground-water section of the  -
criteria.
  Permafrost areas are no longer
addressed in the criteria. While EPA is
concerned with the. effects of solid  . .
waste disposal in permafrost areas
there are several reasons why it is not
appropriate to establish a national
criterion concerning permafrost.
Permafrost areas only occur in Alaska in
the United States. The State of Alaska
has authority to regulate solid waste "
disposal and to protect permafrost. EPA
believes that the State's program is   •;':
adequate to protect these  areas. Under
Section 6001 of the Act Federal facilities
must comply with applicable State solid
waste disposal requirements. Thus,
there should be full compliance with
those State disposal requirements
affecting permafrost areas. Moreover,
the criteria addressing floodplains,
surface water and ground water will
cover many of the environmental effects'
of concern in such areas. Under these
circumstances it does not seem
necessary to establish separate
permafrost criteria at this time.
  In response to the Agency's request,
some commenters described risks   • --•
inherent in disposal of solid waste in
karst terrain and active fault zones. The
concerns raised pertained primarily  to
ground water. The Agency believes that
these concerns are adequately
addressed by the ground-water criteria
and has not provided a separate criteria
for karst terrain or active fault zones. ' •
  In the proposed regulation the     .  '•
criterion for disease just addressed the -•
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 problem presented by disease-carrying
 vectors. In the section addressing food-
 chain crops, the proposed criteria
 provided for controls to reduce the
 likelihood for transmission of pathogens
 from the solid waste to humans. Since
 both provisions concerned the
 prevention of disease, they have been
 combined in S 257.3-6.

 D. Floodplains (Section 257.3-1)
   Disposal of solid waste in floodplains
 may have several significant adverse
 impacts: (1) If not adequately protected.
 wastes may be carried by flood waters
 and flow from the site, affecting
 downstream water quality and
 structures; (2) filling in the floodplain
 may restrict the flow of flood waters,
 causing greater flooding upstream: and
 (3) filling in the floodplain may reduce
 the size and effectiveness of the flood-
 flow retaining capacity of the floodplain,
 which may cause a more rapid
 movement of flood waters downstream,
 resulting in higher flood levels and
 greater flood damages downstream. For
 these reasons it is generally desirable to
 locate disposal facilities outside of
 floodplains.
   The proposed criteria required that a
 facility not restrict the flow of the base
 flood nor reduce the temporary water-
 storage capacity of the floodplain, in
 order to prevent increased flooding
 upstream or downstream resulting from
 the base flood. In addition, the proposal
 required that the facility be protected
 against inundation by the base flood.
 unless the facility is for land application
 of solid waste for beneficial utilization
 as agricultural soil conditioners or
 fertilizers.
   In developing this criterion EPA
 Bought to comply with Executive Order
 11988. "Floodplain Management" (42 FR
 28951), which requires Federal agencies,
 in carrying out their responsibilities, to
 take actions to reduce the risk of flood
 loss,  to minimize the impact of floods on
 human safety, health and welfare, and
 to restore and preserve the natural and
 beneficial values served by floodplains.
 In accordance with Executive Order
 11988. EPA consulted with the Water
 Resources Council and the Federal
 Insurance Administration of the
 Department of Housing and Urban
 Development Both of these agencies
 deal with floodplain management issues.
  A few commenters questioned
 whether floodplain concerns were
 within the statutory scope of these
 regulations. Clearly, improper disposal
of solid waste in a floodplain can have
adverse effects on health and  the
environment. EPA is not aware of any
other Federal program that addresses
the  particular environmental threat
                               presented by solid waste disposal
                               activities in floodplains. Therefore, there
                               is no question that these concerns are
                               within the purview of this regulation.
                                 After evaluating the proposed
                               floodplains criterion in light of the
                               comments, EPA re-evaluated the
                               rationale for the proposed regulation.
                               There was an apparent contradiction in
                               the criterion between the requirement to
                               prevent any increased flooding  and the
                               provision to protect against inundation.
                               As several commenters pointed out.
                               compliance with one was likely to lead
                               to violation of the other. In addition EPA
                               concluded that it was not necessary to
                               eliminate any and  all marginal
                               Increases, however small, in flood levels
                               caused by disposal operations.
                               Moreover, not all inundation of disposal
                               facilities leads to adverse environmental
                               effects. Depending on the waste material
                               there may be no adverse downstream
                               effects: where such effects could occur.
                               proper control measures to prevent
                               washout of the waste materials (e.g.
                               diking) would be sufficient to avoid the
                               problem.
                                Therefore. EPA made the following
                               changes in the floodplain criterion:
                                1. The disposal facility or practice
                               should seek to avoid washout of solid
                               waste, rather than  necessarily prevent
                               inundation of the waste. This change
                               allows for the development of
                               management practices or facility designs
                               that can avoid washout of the solid
                               waste without preventing all inundation
                               by flood waters. (Several commenters
                               indicated that such approaches were
                               feasible.)
                                2. All of the requirements are linked to
                               an assessment of the hazard to human
                               life, wildlife, land or water. This is
                               designed to avoid a situation where any
                               increase in flood levels attributable to
                               disposal activities or washout of waste
                               is automatically precluded. EPA does
                               not believe that the incremental effect of
                               solid waste operations on floodplain
                               management justifies such a drastic
                               approach. In some cases, however,
                              disposal activities may present a
                              significant marginal increase in the risk
                              of flood damage. It  is appropriate to
                              avoid such a risk. EPA cannot specify
                              for all situations what that unacceptable
                              risk will be. This issue must be resolved
                              on a case-by-case basis in the
                              implementation of these criteria.
                                3. The exception for land application
                              of solid waste for beneficial utilization
                              as an agricultural soil conditioner or
                              fertilizer has been eliminated. EPA
                              believes that special exceptions for
                              classes of activities are no longer
                              necessary. In more clearly specifying the
                              performance objective for disposal in
                              floodplains, the criteria provide (he
 flexibility to allow continuation of those
 activities that do not present health and
 environmental hazards.
   Some commenters questioned the use
 of the 100-year base flood in defining the
 floodplain of concern. EPA believes that
 this it an appropriate definition. The
 100-year floodplain does not represent a
 flood that will occur only once in 100
 years. It is the flood which has a one
 percent or greater chance of occurring In
 any one year. Such a flood may occur
 several times or never occur within a
 given 100-year period. In selecting the
 100-year flood to define the floodplain of
 concern EPA is maintaining consistency
 with the approach in other Federal
 programs and in Executive Order 11988.
   Some commenters misinterpreted the
 criteria as a prohibition against locating
 facilities in floodplains. While areas
 other than floodplains are often
 preferable locations for disposal
 facilities, the proposed criteria  did not
 provide such a prohibition. Certainly.
 that point is even clearer in the
 floodplain criterion issued today.

 £ Endangered and Threatened Species
 (Section 2573-2)
   Solid waste disposal activities can
 adversely affect endangered and
 threatened wildlife by releasing toxic
 materials into the  environment  and by
 disrupting the ecosystems on which they
 rely for food and shelter. Therefore. It is
 appropriate for these criteria to contain
 provisions designed to mitigate adverse
 effects  of solid waste disposal activities
 on endangered and threatened species
 of plants, fish or wildlife.
   The proposed criterion was designed
 to ensure that disposal activities did not
 occur in the critical habitats of
 endangered species unless it WBS
 determined that the activities would not
 jeopardize the continued existence of
 endangered species. The proposal also
 required the approval of disposal plans
 by the Office of Endangered Species
 (OES) in the Department of Interior
 (DOI).
   Under Section 7 of the Endangered
 Species Act (ESA). as amended. 16
 U.S.C. 1536, all Federal agencies, in
 consultation with the Secretary of the
 Interior or the Secretary of Commerce,
 are to utilize their authorities in
 furtherance of the purposes of the ESA.
EPA held formal consultations with the
 DOI and received a "biological opinion"
 recommending changes in the criteria.
 EPA considered this recommendation
 from DOI and all public comments in
 setting this criterion.
  EPA has concluded that the criteria
should assure that no solid waste
disposal facilities or practices cause or
contribute to the taking of endangered
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or threatened species. Taking means
harassing, harming, pursuing, hunting,
wounding, killing, trapping, capturing or
collecting, or attempting to engage in
such conduct. In addition such
activitites should not destroy or
adversely modify the critical habitats of
these species. EPA believes  that this
criterion is clearly within the scope  of
the Act and that it satisfies Agency
responsibility under the ESA.
   Some commenters questioned EPA's
authority to address effects  on
endangered species in the criteria. The
Act gives EPA authority to set criteria
concerning the full range of  health and
environmental effects resulting from
solid waste disposal. The taking of
endangered or threatened species by
solid waste disposal activities is
certainly an environmental  effect of
concern. In addition the ESA places a
responsibility on the Agency to use  its
 authority under the Act to mitigate such
 effects.
   The major change in this criterion
 from what was contained in the
proposed regulation is the shift in
 concern to the taking of endangered and
 threatened species. The proposed
regulation focused on avoiding
modifications of critical habitats that
jeopardized the continued existence of a
 species. After examining that approach
 in light of the comments, EPA decided
 that the "jeopardize" language was
 inappropriate for a definition that would
 be applied to a vast number of site-
 specific conditions. In deciding whether
 an act or facility would jeopardize the
 continued existence of a species, the
officials implementing the criteria would
have to examine the marginal effect that
harm to particular members of a species
would have on the national  population
of that species. Particularly  in the case
of the open dump inventory, which
involves the evaluation of thousands of
solid waste disposal facilities, it would
be extremely difficult to implement  a
"jeopardize" standard.
   A determination of whether disposal
activities are "taking" enda'ngered
species is more readily applicable to the
site-specific situations for which these
regulations will be used. Officials
charged with implementing the criteria,
as well as parties engaged in solid
waste disposal, can quickly  determine
what is necessary to achieve
compliance. Such an approach is
consistent with EPA's general intent to
establish concise, measurable
performance standards wherever
possible.
  The use of the "taking" concept does
not reflect an EPA belief that the ESA
requires such an approach. EPA's
obligation under Section 7 of the ESA, if
 any, is to assure that the criteria, which
 provide a national definition o'f the
 unacceptable environmental effects of
 solid waste disposal, do not jeopardize
 endangered species. Where those
 criteria are applied by State agencies,
 such implementation activities are not
 subject to Section 7 because no Federal
 action is involved.
   Some commenters  suggested that in
 complying with Section 7 EPA could not
 set criteria applicable to non-Federal
 parties that are more restrictive than
 what Section 9 of the ESA now requires
 of such parties. (Section 9 prohibits the
 taking of endangered species.) EPA
 rejects that argument. The Act and
 Section 7 of the ESA give EPA authority
 to set criteria different than the
 requirements otherwise applicable
 under Section 9.
   EPA believes that the best way to
 ensure that national populations.of
 endangered and threatened species are
 not jeopardized is to avoid the
 destruction of members of that
 population in site-specific situations.
 While the standard could have been
 written several ways to accomplish that
 objective, EPA believes that preventing
 the "taking" of endangered and
 threatened species has several
 advantages. This approach will aid
 coordination between solid waste and
 endangered species programs where
 feasible. It also gives the regulated
 community a uniform standard defining
 its responsibility in both contexts. The
 "taking" definition is broadly stated and
 thus would encompass the variety of
 adverse effects on endangered and
 threatened species that could be  caused
 by  solid waste disposal. In its
 "biological opinion" DOI endorsed this
 approach.  •
   In the proposed regulation EPA only
 addressed endangered species. Several
 commenters suggested that "threatened"
 species identified by DOI also be
 included for consideration. EPA believes
 that such threatened  species of wildlife
 are also deserving of protection and,
 therefore, has  included them in the
 criteria. Thus,  the endangered and
 threatened species of concern are those
 listed under authority of Section 4 of the
 ESA.
   In endorsing the "taking" language,
 DOI's "biological opinion" included
 exceptions for activities covered by
• permits under  Section 10 of the ESA or
 allowed by Section 6(g)(2] of the ESA.
 Section 10 authorizes the issuance of
 permits for the taking of species "for
 scientific purposes or to enhance  the
 propagation or survival of the affected
 species." The operative portion of
 Section 6(g){2) makes the Section 9
 prohibition of taking inapplicable in
states that have negotiated cooperative
agreements with DOI. Under
cooperative agreement, designated State
officials may take endangered species
for conservation purposes. Since neither
of these situations seemed applicable to
solid waste disposal activities they have
not been included in the criteria.
  EPA has decided  to retain that part of
the proposed regulation that reflected a
concern for the wildlife habitats. Where
"critical" habitats of threatened or
endangered species have been identified
by DOI it is unacceptable under the Act
for solid waste disposal activities  to
destroy or adversely modify such
habitats. In setting this criterion EPA is
not precluding all disposal in a critical-
habitat area.  Only when such disposal
appreciably diminishes the likelihood of
the survival and recovery of threatened
or endangered species using the habitat
does a violation occur. The "biological
opinion" from DOI endorses this
approach.
  EPA has decided  to drop that portion
of the proposed criteria which required
approval of disposal plans by the Office
of Endangered Species, Department of
Interior. EPA agrees with the several
commenters,  including OES, who said
that such a requirement was
inappropriate. The Act and the CWA
create the implementing mechanisms for
these criteria. While the OES may, and
probably should, be consulted on. the
application of § 257.3-2 to particular
situations, the 'officials responsible for
applying the criteria, rather than the
OES, must determine whether a
violation has occurred.
F. Surface Waters (Section 257.3-3)
  It is essential that solid waste
activities not adversely affect the
quality of the nation's surface waters.
Rivers, lakes  and streams are important
as sources of drinking water, as
recreational resources and as habitats
for a wide variety of fish and other
aquatic organisms. The nation's coastal
and inland wetlands provide natural
flood and storm control, sediment  and
erosion control, recharge of acquifers,
natural purification  of waters, and flow
stabilization of streams and rivers.
Wetlands produce nutrients which
support complex ecosystems extending
into estuaries and streams well beyond
the marshes and wetland areas.
Wetland habitats support fish, shellfish,
mammals, waterfowl, and other wildlife
fauna and flora.
  Solid waste disposal has led to
surface-water contamination from runoff
of leachate, accidental spills, and drift of
spray occurring at dumps, landfills,
surface impoundments, farmlands, and
landspreading operations. In the
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 53444    Federal Register  /  Vol. 44,  No. 179  /  Thursday. September  13. 1979 / Rules  and  Regulations
  proposed criteria EPA sought to
  coordinate its surface water standards
  under the'Act with programs developed
  under the Clean Water Act (CWA) to
  restore and maintain the Integrity of the
  waters of the United States (including
  wetlands.)
    The proposed criteria required that
  point source discharges of pollutants
  comply with a National Pollutant
  Discharge Elimination System (NPDES)
  permit issued for the facility according
  to Section 402 of the Clean Water Act. A
  separate section addressed wetlands, a
  particular category of waters of the
  United States. This section, which has
  now been combined with the other
  surface water provisions, required that
  facilities not be located In wetlands
  unless permits were  obtained under
  provisions of Section 402 and/or 404 of
  the Clean Water Act. The proposed
  criteria also required non-point source
  discharges of pollutants to be prevented
  or minimized.
    The final regulation maintains this
  general approach and has eliminated
  those parts of the proposed regulation
  that might have created conflicting
  RCRA and CWA requirements
  concerning  the adverse effects of solid
  waste disposal on surface waters. The
  separate section for wetlands was
  eliminated because they are treated like
  all other surface waters under the CWA.
  The provision affecting non-point source
  discharges to surface water has been
  linked more directly  to applicable
  requirements developed for State and
  areawide water quality management
  planning programs under Section 208 of
  the CWA.
    Under Section 1006 EPA is required to
  integrate, to the maximum extent
  practicable, the provisions of the Act
  with the Clean Water Act and other
  statutes. Under the CWA. EPA conducts
  programs designed "to restore and
  maintain the chemical, physical and
  biological integrity of the Nation's
  water." EPA believes that this goal is
  also a legitimate objective for its
  regulatory activity under the Act and
  that, in the spirit of Section 1006. EPA
  should use its authority under the Act to
  see that the  goals of the CWA are
  achieved. Thus, in defining unacceptable
  solid waste disposal activities, EPA can
  and should determine that facilities and
  practices violating the Clean  Water Act
  cannot be acceptable for purposes  of
 RCRA.
   Thus, in establishing the surface
  water criterion EPA used concepts and
 approaches used under the CWA. The
. surface  waters of concern are the waters
 of the United States, which include
 "wetlands" meeting the Agency's and
 the Corps of Engineers' definition of that
 term. All point source discharges of
 pollutants must comply with
 requirements for NPDES permits
 pursuant to Section 402 of the CWA.
 Discharge of dredge or fill material to
 waters of the United States must comply
 with requirements for permits
 established pursuant to Section 404  of
 the CWA. ("Requirements" under the
 402 and 404 permit programs  include the
 general requirement to apply for such
 permits, as well as the substantive
 provisions of issued permits.) Ncn-point
 source pollution from solid waste
 disposal activities must not be in
 violation of legal requirements
 established to implement a water
 quality management plan under Section
 208 of the CWA. Water quality
 standards developed to satisfy Section
 303 of the CWA may be implemented
 through either NPDES permits. Section
 404 dredge and fill permits, or legal
 requirements developed to implement a
 Section 208 plan.
   Some commenters suggested that  in
 using a CWA-based approach in these
 regulations EPA was attempting to
 regulate discharges to waters of the
 United Slates under the Act. This is
 certainly not the intent or result of these
 criteria. The  implementation of CWA
 programs will be left to those
 responsible for those programs. In these
 criteria EPA  is merely indicating that
 where solid waste activities violate  the
 CWA, as determined by officials
 implementing that law, EPA cannot
 determine that those activities provide
 adequate protection to public health and
 the environment for purposes of RCRA.
   Commenters also expressed concern
 over the definition of "wetlands".
 arguing that man-made channels and
 basins (particularly wastewater
 treatment lagoons) that happen to
 support vegetation should not be subject
 to protection under this criterion. In
 keeping with the goal of coordination,
 EPA is accepting the approach taken
 under the CWA, es expressed in the
 recently issued NPDES regulations (44
 FR 32854). Thus, waste  treatment
 lagoons or other waste treatment
 systems that happen to support
 vegetation are not waters of the United
 States. (As indicated in the NPDES
 regulations, cooling lakes and ponds  are
 generally within  the definition of waters
 of the United States', but certain kinds of
 cooling ponds may be excluded.)
  Several commenters questioned the
 proposed inclusion of "surface runoff
 as a point source discharge of
 pollutants. Under the existing NPDES
regulations the term "discharge of
pollutant" is defined to include	
surface runoff which is collected or
 channelled by man." EPA will maintain
 that approach in these criteria. All other
 surface runoff is subject to applicable
 requirements developed under section
 208 plans for non-point source pollution.
   Several public comments reflected
 concern about what permits would be
 necessary under the CWA for solid
 waste disposal in wetlands. Diking or
 other dredge or fill operations designed
 to prepare an area within waters of the
 United States for disposal of wastes
 would  require a 404 permit as a matter
 of course. A question arises, however.
 concerning the actual deposit of the
 waste material into waters of the United
 States. Such a discharge could be
 treated as a discharge of pollutants
 requiring a Section 402 NPDES permit or
 as a discharge of dredged or fill material
 requiring a 404 permit.
   Under previously issued regulations
 Implementing the CWA (42 FR 37122).
 where the "primary purpose" of the
 discharge of waste material is for
 disposal, rather than for filling an area.
 the discharge is subject to the NPDES
 program.
   Some commenters suggested a need
 for procedures establishing how NPDES
 permits will be applied to solid waste
 disposal. In response the Agency is
 developing policy guidance for this
 permitting process. As  of this writing, a
 draft of this policy guidance. "NPDES
 Permits for Solid Waste Disposal
 Facilities in Waters of the United
 States—Policy Guidance Memorandum.
 August 23.1978." has been distributed
 for external review. A public meeting for
 discussion of the draft policy guidance
 memorandum was held on December 11.
 1978. EPA is currently reviewing the
 public comments submitted  on this"
 issue. EPA is also considering whether
 solid waste disposal in wetlands is more
 appropriately handled under the Section
 404 permit program. EPA intends to
 explore this issue with the Corps of
 Engineers.
   EPA has dropped any reference to a
 presumption against issuance of an
 NPDES permit for discharge of solid
 waste into wetlands. That reference.
 contained as a  comment in the proposed
 regulation, reflected EPA's general belief
 that disposal activities  should not be
 conducted in wetlands if other
 alternatives exist. The NPDES permit.
 however, will define the legal
 responsibilities of parties engaging in
 disposal of solid waste  near or in waters
 of the United States. If the requirements
 of an applicable NPDES permit can be
 satisfied, then there will be no added
 "presumption" against the facility or
practice.
  Commenters raised concerns over the
ability of NPDES permitting agencies to
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         Federal Register /  Vol.  44,  No. 179  /  Thursday,  September  13, 1979 / Rules  and  Regulations   53445
process applications and issue permits
for point source discharges of pollutants
from solid waste disposal facilities. It
was noted that not many NPDES
permits have been issued to such
discharges.
   It has been Agency policy to prioritize
issuance of NPDES permits based on the
potential adverse environmental impact
of the discharge! However, all
discharges require NPDES permits, and
it is incumbent on the discharger to
apply for the NPDES permit. Generally,
no enforcement action is taken if
application for an NPDES permit has
been made, but the permit has not yet
been issued. Upon issuance, the
discharger must maintain compliance
with the NPDES permit. Upon denial_or
revocation of a permit, the discharge
must be discontinued.
   In using the 208 planning program,
EPA has dropped the proposed
requirement to "prevent or minimize"
nonpoint source pollution from solid
 waste disposal activity. Several
 commenters were concerned  that such a
 requirement might duplicate or conflict
with provisions developed to implement
a State water quality management plan.
EPA shares that concern and, therefore,
has made the changes described above.
However, EPA is also aware that not all
208 plans will have addressed the non-
point source pollution problems
presented by solid waste disposal. EPA
intends to explore this problem further
 to determine whether uniform national
guidance is needed and can be given on
how to handle this type of pollution
problem. If a set of standards can be
devised EPA will consider amending
these criteria.
   Not all portions of a 208 plan will
necessarily be applicable to solid waste
disposal activities, and it will be up  to
officials implementing the criteria to
make the appropriate determination.
The criteria are linked only to those
portions of the plan that have been
translated into legal requirements (i.e.
statute, regulation, ordinance,
administrative orders.) This assures
clarity on what is required, avoiding
questions about how to comply with
broadly-stated policy statements.
G. Ground Water (Section 257.3-4)
   Ground water, generally a high
quality, low cost, readily available
source of water, is the drinking water
source for at least one half of the
population of the  United States: often it.
is the only economical and.high quality
water source  available. Ground water is
generally suitable for human
consumption with little or no treatment
necessary.
  Ground water has been contaminated
by solid waste disposal on a local basis
in many parts of the nation and on a
regional basis in some heavily
populated and industrialized areas,
precluding its use as drinking water.
Existing monitoring of ground-water
contamination is largely inadequate;
many known instances of contamination
have been discovered only after ground-
water users have been affected. The Act
and its legislative history clearly reflect
Congressional intent that protection of
•ground water is to be a prime concern of
the criteria.
  The proposed criteria established
requirements for ground-water
protection based on the utilization of the
ground water. Ground-water utilization
was divided into two categories: Case I
addressed ground water currently used
or designated for use as drinking water
supplies or ground water containing
10,000 miligrams per liter (mg/1) total
dissolved solids or less; and Case II
addressed ground water designated for
other uses.
  For Case I, the proposed criteria
required that the quality of ground water
beyond the disposal facility be
maintained for  use as a drinking water
supply. The proposed criteria were
based on the "endangerment" approach
adopted from previously proposed
regulations for  the Underground
Injection Control Program  (41 FR 36726).
"Endangerment" was defined to mean
introduction of a contaminant that
would require additional treatment of
current or future drinking water supplies
or would otherwise make the water unfit
for human consumption. The proposed
criteria required that the disposal
facility not "endanger" Case I ground
water beyond the property boundary.
(Comments were specifically requested
on the use of other distances in lieu of or
in addition to the property  boundary.)
For Case II, States could, where
consistent with their authority,
designate ground water for uses other
than drinking water and would establish
the quality at which the ground water
was to be maintained consistent with
the designated use.
  In order to predict, as early as
possible, the potential for ground-water
endangerment,  the proposed criteria
required that ground water be monitored
so as to indicate the movement of
contaminants from the disposal facility
where endangerment was likely.
Contingency plans were required for
corrective actions to be taken in the
event that an adverse impact was
indicated by the monitoring.
 .For sole source aquifers,  the proposed
criteria required that facilities not be
located in the recharge zone unless
 alternatives were not feasible and
 unless "endangerment" was prevented.
  Under the final ground-water criteria,
 the facility or practice must not
 contaminate an underground drinking
 water source beyond the solid waste
 boundary or an alternative boundary set
 by the State. Contamination occurs
 when leachate from the disposal activity
 causes the concentrations of certain
 pollutants in the ground water to either
 (1) exceed the maximum contaminant
 level (based on the primary drinking
 water standards) specified for that
 pollutant, or (2) increase at all where the
 background concentration of the
-pollutant already exceeds the applicable
 maximum contaminant level. An
 underground drinking water source is an
 aquifer currently supplying drinking
 water for human consumption or an
 aquifer in which the concentration of
 total dissolved solids is less than 10,000
 milligrams per liter (mg/1). Generally,
 the existence of contamination is
 determined at the waste boundary.
 However, States with approved solid
 waste management plans may establish
 an alternative boundary if, after
 thorough examination of the site-specific
 situation, a finding is made that an
 adjustment of the boundary would not
 result in contamination of grour d water
.needed or used for human consumption.
  (1) Approach to Ground-watet-
 Protection. A few commenters suggested
 that the proposed regulation was
 beyond EPA's authority becaue it
 allegedly involved the establishment of
 ambient ground-water standards. This
 charge reflects a misunderstanding of
 the approach taken in the proposed, as
 well as the final, regulation. EPA is not
 regulating ground water with these
 criteria; rather, EPA is setting standards
 applicable to disposal of solid waste. In
 defining  the unacceptable effects  of such
 disposal on ground water, EPA has
 concluded that solid waste activities
 should not degrade ground water
 beyond levels established to protect
 human health. The criteria are designed
 to achieve that objective.
  EPA recognizes that ground-water
 quality is important for other purposes
 (e.g. for irrigation of plants, for its effect
 on fragile ecosystems.) Differing
 standards may be appropriate to protect
 its usefulness for these other purposes.
 At this time, however, EPA has decided
 to define "contamination" in terms of
 the water's use as a drinking water
 source. EPA believes that the prevention
 of adverse human health effects from
 direct consumption of ground water,
 should be the first among several
 objectives in protecting ground-water
 quality. Moreover, the Agency has
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53446   Federal Register / Vol. 44. No.  179 / Thursday, September 13. 1979  /  Rules and Regulations
developed standards for drinking water
but has not established standards for
other uses.
  These criteria reflect EPA's concern
for both present and future users of
ground water. A significant number of
people in  the country take their drinking
water directly from ground-water
resources. EPA expects that such direct
use will continue in the Future. In
defining unacceptable solid waste
disposal activities, these criteria cannot
be based  only on current patterns of
ground-water use. Potential future users
of the aquifer must be considered.
   EPA believes that solid waste
activities  should not be allowed to cause
underground drinking water sources to
exceed established drinking water
standards. Future users of the aquifer
will not be protected unless such an
 approach is taken. Where maximum
contaminant levels have already been
exceeded due to other conditions or
 actions affecting the aquifer, solid waste
 activities should not be allowed to
 increase the risk of damage to present or
future users of the aquifer.
   (2) Contaminants of Concern.
 Commenters stated that the
 "endangerment" standard in the
 proposed regulation was vague.
 especially since it did not specify
contaminants that would make more
extensive treatment necessary or
otherwise make the water unfit for
human consumption. Some felt this
approach would allow too much
contamination, given the lack of
certainty  regarding toxicity of many
contaminants and the state-of-the-art of
monitoring and water treatment. Others
stated that it would require facility
operators to demonstrate protection
from a myriad of substances,  that the
levels to which those substances should
be tolerated was not defined,  that the
standard  was based on unspecified
treatment-and changing technology, and
that the capability of existing treatment
is a function of too many parameters. In
order to respond to these comments the
Agency explored various lists of
contaminants upon  which  to base the '
criteria.
  Several reviewers supported the
proposed  criteria's use of the National
Interim Primary Drinking Water
Regulation (N1PDWR) in the definition
of "endangerment". Some reviewers
pointed out. however,  that the list of
contaminants in the NIPDWR (40 CFR
Part 141) was not created to serve as
ground-water quality standards, and
that it does not include all potentially
harmful substances  which might be
associated with leachule from solid
waste.
  EPA recognizes that the NIPDWR lists
only those parameters commonly found
In public drinking water supplies. Other
substances which may be harmful to
human health were not included in Part
141 due to their relatively rare
occurrence in drinking water systems,
the unsuitability of analytical methods.
the high costs of monitoring, or the lack
of toxicity data. For example, cyanide
was not listed In the NIPDWR because
of its low rate of occurrence. Several
potentially dangerous substances which
were excluded  from the NIPDWR are
present in leachate from waste disposal
  There is no doubt, however, that the
contaminants identified in the NIPDWR
are appropriate for consideration in the
criteria. Generally, no commenters
opposed the inclusion of any listed
contaminant in this regulation. The one
exception is the manmade radionuclides
Identified in the NIPDWR. These
substances fall within the class of
radioactive substances excluded from
the Act's definition of solid waste  and.
thus, the leaching of these  materials into
ground water should not be addressed
by these criteria.
  EPA has evidence that all of the
contaminants identified in th'e NIPDWR
have been in wastes covered by these
criteria and that such materials are
likely to enter ground-water supplies.
Therefore, while it may be advisable to
expand the list of contaminants covered
by the criteria as new information is
developed by the Agency, it is certainly
appropriate to use the contaminants
identified in the NIPDWR in the criteria
at this time.
  The Agency has also explored the use
of the National Secondary Drinking
Water Regulations (NSDWR) in defining
maximum contaminant levels. The
NSDWR (40 CFR Part 143) represent the
Agency's best judgment on the
standards necessary to protect
underground drinking water supplies
from adverse odor, taste, color and other
aesthetic changes that would make the
water unfit for human consumption. EPA
believes that this is a serious concern
which deserves consideration in the
criteria. In addition, many of the
substances listed in the NSDWR often
occur together with other substances in
leachalc which can be injurious to
health.
  However, EPA has decided not to
Include (he contaminants identified in
the NSDWR in the criteria at this time. It
was not clear in the proposed regulation
that EPA was considering their use for
purposes of the criteria. To avoid any
question about the adequacy of
opportunity to comment on the use of
the NSDWR in the criteria. EPA has
decided to specifically seek public
comment on this issue. Thus, EPA is also
issuing today a proposed amendment to
the criteria which would add the
maximum contaminant levels in the
NSDWR to the definition of ground-
water "contamination."
  Two other sets of pollution
parameters were considered for
Inclusion in these criteria: the Quality
Criteria for Water {EPA 1976) and the
list of toxic pollutants referenced in
Section 307(a)(l) of the Clean Water
Act. as amended.
  The publication Quality Criteria for
Water recommends levels for water
quality in accord with the objectives in
Section 101(a) and the requirements of
Section 304(a) of the Clean Water Act.
The primary purpose of that publication
Is to recommend levels for surface water
quality that will provide for the
protection and propagation offish and
other aquatic life and for recreation.
Although recommended levels are also
presented for domestic water supply.
and for agricultural and industrial use.
ground water was not a major
consideration.
  Quality Criteria for Water lists most
of the substances in Parts 141 and 143.
Several of the additional parameters
listed are only of interest in surface
water protection, such as mixing zones
(one third the width of a'stream. 10
percent of the area of a lake. etc.).  •
temperature, and suspended solids.
While several health related substances
that could be present in leachate are
listed (e.g.. boron, beryllium, cyanide.
nickel and several insecticides and
other organics). the recommended limits
are specified for aquatic life protection
and these are not appropriate for ground
water. Furthermore, the recommended
limits were written to be guidance in
developing standards, not to be used as
standards themselves. Therefore. EPA
decided that this list was inappropriate
for these criteria.
  Under Section 307 of the CWA the
Agency may establish either technology-
based or stricter health-based standards
for toxic pollutants identified under
Section 307(a)(l). EPA is investigating
the appropriateness of using the health-
based standards in the criteria. Such
substances as aldrin/dieldrin, DDT.
endrin. toxaphene, benzidine and
polychlorinated biphenyls (PCB's) are
now'subject to section 307 standards.
EPA may be establishing  such standards
for other pollutants some time in the
future. At this time', however, for
purposes of these criteria. EPA will rely
only on established  drinking water
standards.
  (3) Levels of Contamination. While
the  design of the ground-water criteria is
similar to the "endangerment" approach
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         Federal Register  /  Vol. 44,  No. 179  /  Thursday, September 13,  1979 / Rules and  Regulations   53447
of the Underground Injection Control
Program under the Safe Drinking Water
Act, it provides for greater specificity
and does not use the exact wording of
that program or statute. Therefore, to
avoid confusion the term
"endangerment" is no longer used in the
criteria. Instead, the word
"contaminate" has been employed. A
facility "contaminates" ground-water if
it introduces a substance that would
cause:
   (a) The concentration of that
substance in the ground water to exceed
specified maximum contaminant levels,
or
   (b) An increase  in the concentration of
• that substance in the ground water
where the existing concentration of that
substance exceeds the specified
maximum contaminant level.
   The first part of the above definition is
intended to protect water that can be
used as drinking water without
 treatment. The second part is intended
to protect ground water already at or
 above the maximum contaminant level
by preventing introduction of substances
 that would exacerbate the problem.
   Many comments were received on
levels of contamination. Some suggested
 using the maximum contaminant levels
 (MCL's) in the National Primary and
 Secondary Drinking Water Regulations;
 others suggested using higher limits or
using lower limits. Some reviewers
suggested varying the levels with the
background quality or the potential use
of the ground water.
   The reasons given for adopting higher
allowable levels, or more lenient
standards, (than the MCL's)  included
contention (1) that the increased cost of
land disposal would be greater than the
value of the threatened resource; (2) that
the more efficient  approach for some of
the substances was to remove them
from the water supply by treatment after
contamination; and (3) that some of the
Secondary MCL's  are commonly
exceeded in ambient or native ground
water, thereby effectively resulting in a
non-degradation standard for those
aquifers. EPA sees no reason to doubt
that some people will continue to
consume ground water directly without
treatment. That portion of the public
should be protected from adverse effects
(as defined by the  drinking water
standards) caused by solid waste
leachate entering their drinking water.
In some situations  protection of the '
public will require  non-degradation of
an aquifer. The Act does not call for a
balancing of the costs of disposal
against the "value" of ground-water
resources. EPA believes that this
criterion represents a reasonable
approach to ground-water protection. It
allows for the use of natural
mechanisms (e.g. soil attenuation,
diffusion of contaminants in the aquifer)
to reduce the risk of adverse health
effects without compromising the
general objective of protecting drinking
water supplies.
  The reasons given for more stringent
limits included: (1) Land disposal
facilities are but one of several sources
of ground-water contamination, and
each source contributes to the overall
rise in contaminant levels, (2) future
research may find  that lower levels are
necessary to adequately protect health,
(3) some agricultural, industrial and
other important uses of ground water
may be imp'aired, and (4) since ground
water is often consumed without
treatment, more stringent limits would
require  less reliance on programs to
monitor and to require treatment before
domestic usage.
   Generally, EPA has not written more
stringent standards because existing
information does not indicate that such
standards are needed to protect public
health. Future research results might, of
course,  justify-changing the criteria. As
discussed earlier EPA does not now
have the scientific basis for setting
stricter standards designed to protect
ground-water's use for non-drinking
water purposes. The standard does
recognize that an aquifer may be
polluted by several sources. Where
existing ground-water quality levels
exceed  the MCL's, the solid waste
activity may not degrade ground-water
quality at all. No matter what the
standard, the need for monitoring must
be determined on a case-by-case basis,
and it seems doubtful  that differing
standards would change that need.
  Some reviewers  mentioned  that
relying only on upper water quality
limits results in more stringent
requirements for protection of
contaminated water than for
uncontaminated water (i.e. facilities
over uncontaminated waters could
introduce substances up to the
maximum contaminant levels, while
facilities over contaminated waters
could not introduce any substance that
would increase contaminant levels).
While this is a possible result  of the
standard, EPA does not believe that the
health risk justifies a complete non-
degradation standard.
  In adapting the NIPDWR for the
criteria a few modifications were
necessary. As indicated earlier the  "
standards for man-made radionuclides
were not included because the statutory
definition of solid waste excludes such
materials from the Act's scope. The
contaminant level for coliform bacteria
had to be modified because under the
 NIPDWR the MCL varied somewhat
 depending on sampling frequency and
 community size. EPA assumed that
 sampling of ground water around
 disposal sites would be less frequent
 than in a public water system, and so
 the NIPDWR coliform standard related
 to the least frequent  sampling regimen
 was selected for the  criteria. Also, the
 criteria do not include the NIPDWR limit
 for turbidity, since that limit was
 established for surface water supplies.
   (4) Where the Standard is Applied.
 Another concern regarding  the ground-
 water criterion is the issue of where the
 standard is to be applied (i.e. at what
 point in the aquifefdoes contamination
 from the facility or practice constitute
 non-compliance). In  the proposed
 criteria, the point of  application was at
 the facility property  boundary. The
 rationale for applying the standard at
 the property boundary was that it would
 provide for protection of off-site ground
 water while affording the opportunity
 for natural soil attenuation  and
 dispersion and dilution of leachate in
 ground water underlying the area
. designated for waste deposition (Le.
 within the facility).
   However, the proposed criteria
 recognized that monitoring  and control
 of leachate within the property
 boundary would generally be \ ocessary
 in order to assure thai the standard at
 the property bountary would be met
 Therefore, there also were proposed
 operational requirements including
 monitoring of ground water, prediction
 and control of leachate migration, '
 collection and removal of leachate and
 prevention of water infiltration.
   Commenters  indicated two potential
 shortcomings of the facility property
 boundary approach:  (1) That future
 owners of the facility property might use
 contaminated ground water underlying
 the facility as drinking water and (2)
 that if the facility property were very
'large, great expanses of ground water
 could be contaminated and purchase of
 additional property could be used to
 circumvent the  intent. EPA agrees that
 such results could  occur.
   Commenters  also expressed concern
 that the operational controls and
 monitoring provisions were vague and
 could be meaningful  only if specified on
 a site-by-site basis, rather than
 generally prescribed in a regulation of
 national applicability. Commenters also
 described these operational provisions
 as inappropriate to a regulation which
 must delineate acceptable performance
 levels.
  The Agency considered use of other
 distance specifications in lieu of the
 property boundary in order to try to
respond to reviewers' concerns about
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 53448   Federal  Register / Vol. 44. No.  179 / Thursday.  September 13, 1979  / Rules  and  Regulations
 the potential for contamination of large
 expanses of ground water. The proposed
 criteria requested comments on
 alternative distances and the rationale
 for specification of such distances.
 Various distances were suggested in the
 public comments: however, there was no
 basis presented for selection of one
 distance over another. While there is a
 rationale for limiting migration of
 contamination to within the areas to be
 used for waste disposal in order to
 protect neighbors who may use the
 ground water untreated as a drinking
 water supply, there is no rationale for
 limiting migration to my particular
 distance.
   In evaluating this issue EPA
 recognized that the point of application
 of the standard must be mindful of the
 ablility  to monitor at that point. Ideally.
 the best way to protect present and
 future users of an aquifer is to assure
 that drinking water standards are not
 violated anywhere in the aquifer,
 including the area immediately under
 the waste material.
   However, any attempt to monitor
 directly under the waste presents two
 major difficulties. First, an
 environmental risk may be posed by the
 installation of monitoring wells through
 the waste material or in areas where
 waste will be deposited. These wells
 may become conduits for direct flow of
 waste constituents (e.g. leachate) into
 the  aquifer. While it may be
 theoretically possible to construct a well
 tho° doesn't allow such infiltration, the
 technology for this has not been
 sufficiently demonstrated that EPA
 would want to encourage this practice
 on a national scale. Secondly, the    ,
 immediate proximity of waste to the
 well, in  conjunction with the "conduit"
 phenomenon, would undermine the
 utility of the monitoring well. Samples
 extracted would not  be likely to be
 representative of the aquifer,  rather,
 they would be likely to contain
 concentrated Icachale. overestimating
 the contamination of the aquifer.
   EPA also examined the possibility of
 other  fixed distances  from the center of
 the waste area. This  approach was
 rejected because it was impossible to
 establish a uniform distance that would
 be meaningful for the vast number of
 situations to which this standard
 applied.  In some instances a fixed
 distance would mean that monitoring
 wells would still be placed through
 waste material. A longer distance might,
 in some cases, put the point of
 measurement beyond  the area of likely
 placement of drinking water wells.
  After examining all  of these
 approaches EPA concluded that the
solid waste boundary is the appropriate
 point for application of the standard.
 The solid waste boundary is intended to
 be taken as the outermost perimeter of
 the solid waste as it would exist at
 completion of the disposal activity.  With
 that as the point  of measurement.
 ground-water contamination will be
 detected as soon as possible without
 presenting the risks inherent in
 monitoring under the waste. Likewise. It
 avoids the problem of guessing the
 distance at which a potentially affected
 party is likely to  put a drinking v/ater
 well. (The only assumption is that
 drinking water won't be taken from
 wells drilled directly  through the area of
 solid waste deposition.)
   In most cases,  for disposal facilities.
 the solid waste boundary would be  the
 boundary of the solid waste as shown
 on the design and operating plans which
 are provided to and approved  by the
 State agency as part of the State's
 facility permitting or certification
 program. Where such plans do not exist
 to designate the perimeter at
 completion, especially for the practice of
 indiscriminate or unauthorized disposal.
 the perimeter at completion can only be
 taken as the current boundary of the
 deposited waste.
   With this approach to the point of
 application for the MCL's. the
 monitoring requirements are relatively
 clear. Monitoring wells should be placed
 so as to avoid their becoming conduits
 for waste materials..Unsaturated and
 saturated zones underlying the area of
 the facility designated for waste
 deposition (i.e. within the solid waste
 boundary) may be employed for
 attenuation or control of leachate   •
 migration, but contamination of
 underground drinking water sources
 outside of these zones constitutes non-
 compliance with the criteria.
   The point of application of the MCL's
 may be modified under certain
 circumstances. EPA recognizes that
 hydrogeological conditions, property
 rights or legal arrangements concerning
 an aquifer may limit the ability of the
 public to directly  use some or any part
 of a particular aquifer as a drinking
 water source. EPA believes that some
 flexibility is needed in the criteria to
 provide for such situations. Therefore,
 the criteria allow  the State to modify the
 point for application of the MCL's.
  To prevent this  from becoming a
 major loophole, the criteria establish
 limits to  this flexibility. Only States with
 approved solid  waste management-
plans may modify the  point of
measurement. This may only occur
where the Stale has conducted  a
thorough examination of the site-specific
situation and has made a specific
finding that establishment of the
 alternative boundary would not result in
 contamination of ground water needed
 or used for human consumption. The
 examination leading to the finding
 should include the opportunity for public
 participation. The criteria specify the
 key factors that must go into this
 determination.
   The proposed criteria would have
 allowed a State to designate an aquifer
 as a Case II aquifer (an aquifer
 designated for use other than as a
 drinking water supply). For an aquifer so
 designated, the proposed criteria
 required the ground water to be
 maintained at a quality as specified by
 the State.  Several comnenters
 challenged the use of this approach.
 Some argued  that, given the
 uncertainties  in future drinking water
 needs,  all  potentially usable drinking
 water should  be conserved. They also
 pointed out that there was inadequate
 data on ground-water quantity, quality
 and use projections to make such
 designations and that institutions and
 authorities to make such trade-offs are
 non-existent.  Commenters also
 suggested that it was improper for the
 criteria to defer totally to State
 standards for designated aquifers.
   EPA generally agrees with the
 comments. These and other factors lead
 EPA to drop the aquifer designation
 provision and rely on the alternative
 boundary approach as the means for
 allowing flexible application of the
 criteria.
   (5) Underground Drinking Water
 Source. The final criteria maintain the
 general approach found in the proposed
 regulation. The reference to aquifers
 that "may be designated by the State for
 future use  as a drinking water supply"
 has been deleted. EPA concluded that
 this was unnecessarily vague. Any
 future drinking water source would be
 likely to fall wilhin the second portion of
 the definition  (aquifers in which ground
 water contains less than 10.000 mg/1
 total dissolved solids).
   Some commenters questioned the use
 of the 10.000 mg/1 total dissolved solids
 measure for usable aquifers. It is the
 Agency's general policy that ground-
 water resources below that
 concentration  be protected for possible
 use as a drinking water source. This
 policy is based on the Safe Drinking
 Water Act and its legislative history
 which reflects clear Congressional
 intent that  aquifers in  that class deserve
 protection.
   (6) Sole Source Aquifers. These
 aquifers are those which the
Administrator specifically designates
under authority of Section 1424(e) of the
Safe Drinking Water Act (Pub. L 93-523-
42 U.S.C. 300f.  300h-3(e): 88 Slat. 1660 et'
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         Federal Register / Vol. 44, No.  179 / Thursday,  September  13, 1979 / Rules  and Regulations   5.1J49
scq.). This provision of the Safe Drinking
Water Act is administered through
regulation's proposed as 40 CFR Part 148.
As applied through RCRA, the Agency's
concern for the impact of disposal
facilities on these aquifers is not
different from that for other
underground drinking water sources as
defined in the criteria. Therefore, for
clarity and consistency, this area of the
proposed criteria has now been
incorporated into the ground-water
section. Rather than addressing the
location of facilities in recharge zones of
such aquifers (an operational standard),
the criteria apply the performance
standard described above for all
underground drinking water sources,
including sole or principal drinking
 water sources, regardless of location.

H. Application To Land Used For The
 Production Of Food-Chain Crops
 (Section 257.3-5)
   The conservation of the nation's
 natural resources is one of the Agency's
 highest priorities. The application of
 sewage sludge, as well as other solid
 wastes, to the land surface or
 incorporation within the root zone of
 crops may provide significant benefit
 through the addition of organic matter,
 nitrogen, phosphorus and certain other.
 essential trace elements to the soil.
 Specifically, land application of solid
 waste coupled with good management
 techniques for enhancement of parks
 and forests and reclamation of poor or
•i damaged terrain is a desirable land
 management technique.
   Application of solid waste to
 agricultural lands may also be an
 environmentally acceptable method of
 disposal. However, when improperly
 managed, the application of solid waste
 to agricultural lands can create a
 potential threat to the human food chain
 through the entry of toxic elements,
 compounds, and pathogens into the diet.
 (It should be noted that pathogens are
 covered under the Disease section of the
criteria.) In developing these criteria, the
Agency attempted to achieve the
•benefits of resource conservation while
at the same time providing for protection
of public health and the environment. In
recognition of the above public health
concerns, the Agency prefers the
application of solid waste to non-food-
chain land rather than to agricultural
lands. However, the Agency believes
that food-chain land application
practices  which comply with these
criteria will pose no reasonable
probability of adverse effects on public
health or  the environment.
   This section is only concerned with
disposal activities affecting food-chain
crops. The other sections of the criteria
apply to all disposal activities, including
those occurring on lands producing
food-chain crops. However, solid waste
facilities, and practices are only affected
by this section if the site of disposal is
also a field for production of food-chain
crops.
   In their role as guidelines under
Section 405 of the Clean Water Act the
criteria define the responsibility of
owners and operators of POTW's when
they apply sewage sludge directly to the
land. In an effort to encourage the
beneficial use of sludge in small
communities EPA is concerned that
.these criteria could present an
unwarranted administrative burden
upon such communities. Therefore, EPA
will explore the possibility of reducing
monitoring and recordkeeping
requirements for those POTW's with
small design capacity which do not have
significant industrial inflow and which
generate a sludge with a low
contaminant level. Such reduced
requirements for facilities which apply
sludge to land used for the production of
food-chain crops would be a part of
future regulations or guidance designed
to implement Section 405. EPA is
considering using a design capacity of
1.0 million gallons or less per day to
define "small" facilities and cadmium
concentrations of less than 25  mg/kg
(dry weight) to define "low-
contaminant" sludge.
   This section of the criteria is being
issued today as an "interim final"
regulation. This means that, while the
regulation is "final" and legally
enforceable, EPA is seeking further
public comment on the regulation. If
changes are warranted by suggestions
or new information generated during the
public comment period, EPA is quite
willing to modify this section.
   The "interim final" approach has been
recognized by the courts as a
permissible means for EPA to use when
trying to satisfy the competing demands
placed on its rulcmaking efforts.
Particularly where EPA is under court
order to issue regulations by certain
dates, this approach has been used to
satisfy the spirit of the court's order
without curtailing opportunity  for
additional public participation in the
rulemaking process.
   These criteria are subject to  the
mandate of the U.S. District Court for
the District of Columbia in State of
Illinois v.  Costle, No. 78-1689 (D.D.C.
Jan. 3,1979). Under the order of that
court the criteria were to be issued by
July 31.1979, and EPA intends  to satisfy
the spirit of that order. EPA believes
that the standards established  in this
section provide a reasonable approach
to the environmental problem at issue.
 However, the public has not liad a full
 opportunity to comment on some of the
 technical data and analyses supporting
 this portion of the regulation. The
 "interim final" approach is appropriate
 because it allows the Agency to
 accommodate these two competing
 interests. It achieves substantial
 compliance with the court mandate
 while allowing full public participation
 in the rulemaking effort.
   As proposed, this section of the
 criteria addressed four general
 categories of pollutants: (1) Cadmium;
 (2) pathogens; (3) pesticides and
 persistent organics; (4) ingestion of toxic
 organic chemicals and heavy metals
 (especially PCB's and lead). In the final
 regulation this section addresses
 cadmium and PCB's. Pathogens are
 considered under the disease criterion
 (§ 257.3-6).  Lead, pesticides and
 persistent organics will not be
 addressed at this time because current
 information available to the Agency is
 inadequate to support specific
 standards. EPA will investigate the
 possibility of adding more pollutants to
 the criteria  at a later date.
   (1) Cadmium.—The proposed criteria
 included two approaches for the land
 application of solid wastes containing
 cadmium. The first approach
 incorporated four site management
 controls: Control of the pH of the solid
 waste and soil mixture; annual cadmium
 application limits that were reduced
 over time; cumulative cadmium
 application limits based on soil cation
 exchange capacity (CEC); and a
 restriction on the cadmium
 concentration in solid wastes applied to
' facilities where tobacco, leafy
' vegetables and root crops are grown.
 The second approach required
 comparability of the cadmium content of
 crops and meats marketed for human
 consumption to the cadmium content of
 similar crops and meats produced
 locally where solid waste had not been
 applied.  Also, a contingency plan was
 required which identified alternative
 courses of action  that would be taken if .
 the cadmium levels were not found to be
 comparable. This approach was only
 available to facilities possessing the
 necessary resources and expertise to
 adequately manage and monitor their
 operations to assure such comparability.
   In the  final regulation, application of
 solid waste to land is specified as a
 disposal practice in which the solid
 waste is applied to within one meter
 (three feet) of the surface of the land.
 That distance was selected to represent
 the root zone of food-chain crops, where
 uptake of cadmium by plants is likely to
 occur.
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 53450   Federal Register  /  Vol. 44.  No. 179  /  Thursday.  September 13. 1979  /  Rules and Regulations
   The final regulation maintains the
 same general approach as the proposed
 regulation. Under the first option
 controls are placed on both annual
 application rates and maximum
 cumulative loadings. The provision
 mandating that the pH of the mixture of
 soil and solid waste be maintained at 6.5
 has been changed to a requirement that
 the pH be at 6.5 or more at the time of
 each'solid waste application (except
 when cadmium concentrations are 2 mg/
 kg or less in  the solid waste).
   While the  annual application rate
 limits are basically the same as those in
 the proposed regulations, (wo changes
 have been made. The limit for annual
 cadmium application to "accumulator"
 crops is now 0.5 kilograms per hectare/
 yr. (In the proposed regulation the limit
 was expressed in milligrams per
 kilogram dry weight of waste.) In
 addition, the annual application rate
 'limit for all other crops will be phased in
 over a slightly longer time period than
 that which was proposed.
   The limits on cumulative loadings are
 also basically the same as those in the
 proposed regulation. However, they
 have been modified to account for pH
 effects. Where natural soil background
 pH is at 6.5 or greater,  or where the
 natural soil background pH is less than
 6.5 but safeguards exist at the site which
 will assure that the soil pH will be
 maintained at'6.5 or greater for as long
 as food-chain crops are grown, the
 maximum limits contained in the
 proposed regulation are applicable. In
 all other situations  maximum
 cumulative loadings may not exceed 5
 kg/ha.
   As in the proposed regulation, there is
 a second approach  that would allow
 unlimited application of cadmium
 providing that four specific control
 measures are taken: First, the crop
 grown can only be used as animal feed.
 Second, the pH of the soil must be
 maintained at 6.5 or above for as long as
 food-chain crops are grown. Third, a
 facility operating plan must describe
 how the animal feed will be distributed
 to prevent human ingestion. The plan
 must also describe measures that will be
 taken to prevent cadmium from entering
 the human food-chain due to alternative
 future land uses of the site. Fourth.
 future owners are provided notice
 (through provisions  in land records or
 property deed) that  there are high levels
 of cadmium in the soil and that food-
 chain crops should not be grown.
  EPA received many comments on the
 cadmium controls in the proposed
 regulation. In  order to clearly explicate
 the final standard and respond to major
public comment, this preamble will
discuss the issues under five headings:
 (a) Health effects: (b) trace amounts of
 cadmium: (c) maximum cumulative
 loadings; (d) annual rates of application;
 and (e) closely controlled facilities.
   (a) Health Effects of Cadmium.—The
 comments that were received exhibited
 widely divergent views on the health
 implications of cadmium contained in
 solid waste. As a result, the Agency
 reexamined the available scientific data
 and reached the following conclusions.
   A variety of adverse health effects
 have been documented in humans and
 experimental animals under conditions
 of acute as well as chronic exposure to
 cadmium. While acute health effects in
 humans are generally caused by high-
 level occupational exposure through
 inhalation, chronic health effects may
 result through the diet and cigarette
 smoking, which are the major routes of
 cadmium intake for most people. The
 kidney is considered the main target
 organ for chronic exposure to cadmium.
 although chronic respiratory effects
 have been observed in long-term
 occupational settings. Upon ingestion or
 inhalation, the metal gradually
 accumulates in the kidney cortex.
 According to both clinical-
 epidemiological and model-calculation
 data, the critical concentration of
 cadmium in the kidney cortex is
 approximately 200 micrograms per gram
 (ug/g). wet weight, in the average
 human. At that level, renal tubular
 dysfunction, characterized by
 proteinuria. is expected to occur. This
 condition is manifested by the excretion
 of B,-microglobulin. which is the earliest
 discernible laboratory evidence of organ
 damage. Although mild or moderate
 increases in excretion of B,-
 microglobulin. per se. are not life-
 threatening, the condition is often
 irreversible, and continued excessive
 exposure to cadmium can lead to other
 renal function  abnormalities (such as
 glycosuria. amino-acid uria. and
 phosphaturia).
   Several autopsy studies have been
 performed to determine the cadmium
 content of various types of body  tissue.
 such as the kidney and the liver.  These
 studies confirm that the kidney is the
 organ which contains the highest
 concentration of cadmium and that the
 concentration of the metal increases
 with age. Further,  the autopsy data
 Indicate that for the general United
 Slates population  (smokers included)
 the mean cadmium levels reached in the
kidney cortex are  in the range of  20-35
micrograms per gram wet weight.
Smoking would tend to raise the mean
cadmium concentration since the data
also show that  smokers have
approximately  double the concentration
 of non-smokers. There were significant
 Individual variations from the mean
 value, with some concentrations over 60
 micrograms per gram.
   Various models have been established
 to calculate the daily level of exposure
 which will result in a cadmium
 concentration of 200 ug/g in the kidney
 cortex, i.e.. the concentration at which
 tubular proteinuria can be expected to
 occur. EPA scientists reviewed these
 models and have reached the following
 consensus. Ingestion of 440 micrograms
 of cadmium per day over a 50-year
 period is a reasonable estimate of the
 amount of cadmium necessary for 50
 percent of the individuals within the
 population  to develop proleinuria. It is
 significant to point out. however,  that
 there are many-individuals who may
 develop proteinuria at lower exposure
 levels. The  metabolic model, developed
 by Friberg.  shows that ingestion of
 about 200 micrograms per day over a 50-
 year period is the level at which most
 sensitive individuals accumulate 200 ug/
 g cadmium  in the kidney cortex. The
 dose-response model developed by
 Kjellstrom and Nordberg. reflects a non-
 threshold dose-response. Using this
 model, daily cadmium exposures in the
 range of 100 to 125 micrograms would
 produce renal dysfunction in about 5 to
 6 percent of the population after some 50
 years of exposure.
   These model calculations are based
 on the assumption that all cadmium
 intake is through the diet. Therefore,
 allowances are necessary for non-'
 dietary routes of cadmium intake, such
 as smoking or occupational exposure.
 (The contribution of smoking to
 cadmium intake is readily quantifiable.
 Available data show that smoking one
 pack of cigarettes a day is roughly
 equivalent to cadmium retention in the
 body resulting from a dietary intake of
 25 micrograms.)
   In 1972. the World Health
 Organization (WHO) used a model such
 as the ones referred to above to arrive at
 a recommended maximum cadmium
 intake level through the diet. Employing
 a margin of safety to allow for non-
 dietary intake sources and for sensitive
 individuals, the WHO recommended
 that  human exposure to cadmium should
 not exceed 57 to 71 micrograms per day
 from the diet.
  There is no general consensus on the
 current dietary cadmium levels in  the
 United States, but there is wide
 agreement that the daily intake levels
 va,ry significantly according to
 Individual dietary habits.  Based on
 annual market basket surveys
conducted by the Food and Drug
Administration (FDA), the median
ingeslion level is about 30 microgrsms
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         Federal Register  /  Vol.  44,  No. 179  /  Thursday,  September  13, 1979 / Rules  and  Regulations   53431
 per day and the mean ingestion level is
 about 72 micrograms per day for male
 teenagers, who have the highest per-
 capita food intake among any age group.
 Any average value as an estimate for
 cadmium intake through the diet has the
 shortcoming  that it does not represent
 those individuals with unusual dietary
 habits, such as the heavy consumption
 of cadmium-rich foods (e.g., leafy
 vegetables); and the available evidence
 shows that there is a wide range of
 dietary cadmium exposure among the
 population.
   One other  source for estimating
 cadmium intake levels in the human
 body was reviewed by the Agency. This
 comprises chemical analysis of fecal
 excretions. The fecal excretion  studies
 are based on the experimental finding
 that only about 6 percent of ingested
 cadmium is retained in the body, while
 the rest is excreted. Three recent fecal
 excretion studies derived the daily mean
 dietary cadmium intake estimate of
 about 20 micrograms for American
 teenage males. The reasons for the
 significant differences between the
 results of the fecal excretion studies and
 the FDA market basket surveys are not
 yet understood. The fecal excretion
 studies also showed significant
 individual variations in derived
 cadmium ingestion levels. Thus, five
 percent of the population appeared to
 exceed 30 to 40 micrograms per day
 intake, and one percent appeared to
 exceed 50 micrograms per day intake.
   There are population groups for whom
 an increase of cadmium levels in the
 diet may be more significant than for the
 average population. Among these are
 the smokers, who are known to receive
 an added body burden of cadmium via
 inhalation. Vegetarians also may be
 experiencing higher cadmium intake
 than the average population, since
 certain vegetables contain significantly
 more cadmium than other food items.
 Also, the scientific literature indicates
 that certain nutritional deficiencies,
 such as low calcium, zinc, or protein.
 result in a marked increase in cadmium
 absorption through the gastrointestinal
 tract, while individuals with vitamin D
 deficiency are more susceptible to injury
 by a given level of cadmium in the body.
   Both the FDA approach and the fecal
 study approach are legitimate means of
 estimating current average intakes of
 cadmium. However it is alscr clear that
 "sensitive" individuals may be
 experiencing much higher absorption of
 cadmium. Since under this regulation
 higher estimates of current intake will"
 mean that lower levels of cadmium will
 be allowed to be added from solid waste
'disposal. EPA believes that it should use
the higher estimate of current diet levels
in order to provide greater protection for
sensitive individuals. Therefore, as will
be explained later, the criteria will rely
on the FDA estimate of 39 ug/day as the
median level in the diet, which was
derived by averaging the median levels
over several years.
  In addition to the concerns over renal
toxicity, several commenters raised
questions over potential oncogenic,
carcinogenic, mutagenic and teratogenic
effects of cadmium. Based on an
evaluation of the currently available  •'
scientific data, the Agency has
concluded that the evidence that
cadmium may-cause these effects in
man is suggestive but not decisive
enough to serve as the basis for this
regulation. Consequently, the limitations
on cadmium incorporated in the criteria
are based on the substantial evidence of
that metal's  impact on the kidney,
specifically the renal cortex, which the
Agency considers to be the main target
organ for chronic environmental
exposure. However, if cadmium is
determined to cause the aforementioned
effects in humans, the Agency will
reevaluate the regulations and establish
appropriate new limits.
  The Agency is concerned over the
conduct of any practice which could
significantly increase the  amount of
cadmium in  the diet beyond current
levels. Therefore, it is the intent of this
rulemaking to minimize the movement of
cadmium into the human food chain
from solid waste applied to the land.
After an evaluation of the full range of
scientific information concerning
cadmium, EPA has decided  to make the
following assumptions to serve as a
basis for setting limits on solid waste
application.
  First, the Friberg model, which defines
200 ug/day as the "danger level" in the
human diet, is most appropriate for
regulatory purposes. There is more data
to validate that approach than there is
for the Kjellstrom dose-response model.
  Second, to provide an adequate safety
margin in defining the risk from solid
waste applied to food-chain crops, the
criteria should be concerned about daily
dietary intake of 70 ug/day of cadmium.
  Third, for analytical purposes, EPA
will assume a maximum increment of 30
ug/day in conjunction with high risk diet
assumptions. In order to relate the
health effects analysis to the diverse
and complicated data that exist on crop
uptake, it is necessary to make a
judgment about the incremental
cadmium ingestion that must be
prevented by this regulation. Clearly,
this is a difficult task in light of the
various sensitivities of particular
individuals, the long-term nature of the
health risk and the various dietary
patterns which may occur.
  In using this assumption, EPA is not
stating that such an increase in the diet
of the average American is acceptable.
An increase of that magnitude in the
average diet would clearly be
unacceptable. For the average to
increase by this increment, many
individuals would be experiencing much
higher cadmium intakes.
  It must be emphasized that the 30 ug/
day figure will be used in an analysis of
a high-risk situation. That high-risk
situation is one where an individual
receives 50% of his vegetable diet from
sludge-amended soils for a period of 40
to 50 years. While such a situation could
occur, due to a wide variety of other
mitigating factors most people will
experience much smaller exposures to
cadmium.
  Realizing'that any numerical
expression of unacceptable health risk
can only be an approximation, EPA used
the 30 ug/day as a reasonable
assumption for this analysis. The
Agency's Office of Research and
Development determined that  daily
cadmium intake of about 200 ug/day
could lead to serious health effects. To
provide a  margin of safety, that office
suggested that a limit of 150 ug/ iay  from
all sources of exposure be considered
for regulatory purposes. EPA is also
concerned about the added cadmium
which may enter the human body due  to
smoking. Heavy smokers (those smoking
3 packs of cigarettes per day) can expect
to add the equivalent of 75 ug of
cadmium to their daily intake.
  Reducing the 150 ug/day by that figure
gives an estimate of the "danger level"
for dietary intake. The result of that
calculation (75 ug/day) is close to the
World Health Organization's
recommendation of 57-71 ug/day. EPA
decided that a level of 70 ug/day
represented a reasonable limit on the
maximum acceptable daily dietary
intake of cadmium. The FDA's estimate
of current levels of cadmium in the
median American is 39 ug/day.
Therefore  the 30 ug/day assumption
would keep cadmium ingestion within
the limit of 70 ug/day.
  (b) Trace Amounts of Cadmium.—
Where the cadmium content of sludges
is quite small the likelihood of a
significant uptake in plants is also
relatively small. Several commenters
suggested  that the requirement for pH
control (6.5 at time of waste application)
should not apply to those solid wastes
which contain only trace amounts of
cadmium. EPA agrees with this
comment and, therefore, has exempted
wastes with cadmium concentrations of
2 mg/kg (dry weight) or less from the pH
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     12   Federal Register  /  Vol. 44.  No. 179  /  Thursday, September  13. 1979 / Rules  and Regulations
53452
 control provision. This modification
 would allow such.wastes as food
 processing residuals to be londsprcad
 without unnecessary pH control
 measures.
 -  (c) Maximum Cumulative Loadings of
 Cadmium.—Comments received on the
 cumulative cadmium application limits.
 soil pH, and soil cation exchange
 capacity (CEC) are interrelated and,
 therefore, will be discussed
 concurrently. In general, commentcrs
 felt that varying degrees and
 combinations of the three
 aforementioned parameters will limit
 the uptake of cadmium by food-chain
 crops.
   Most commentcrs agreed that it is
 necessary to control the pH of the solid
 waste/soil mixture to minimize the
 uptake of cadmium by food-chain crops.
 The final regulation recognizes that need
 by requiring (hat the pH of the soil/solid
 waste mixture be 6.5 at the time of
 application. The proposed regulation
 required that pH be maintained at 6.5 for
 as long as food-chain crops were grown.
 Several commenters pointed out that
 such a provision would be difficult to
 implement or enforce in many
 situations. The Agency agrees that this
 may be true in some instances but did
 not want to preclude the application of
 solid waste to food-chain crops where
 soil pH can be maintained at acceptable
 levels.
   These considerations prompted EPA
 to modify the standard for cumulative
 loadings to delineate three soil
 categories based on pH: (1) Those with
 natural pH of 6.5 or above: (2) those
 with natural pH below 6.5: and (3) those
 with natural pH below 6.5 but where pH
 'will be maintained at or above 6.5 for as
 long as food-chain crops are grown. The
 criteria establish the same set of
 standards for categories (1) and (3) but
 tighten the standard for soils with the
 more dangerous condition reflected in
 category (2).
   The prime data base for the
 calculation of acceptable cumulative
 loadings was a set of field studies on
 former laodspreading sites where crops
 were grown at least two years after
 application of solid waste. This
 approach was appropriate for setting
 maximum cumulative limits because
 such standards are primarily concerned
 with future uses of landspreading sites
 for home gardening or commercial
 agriculture.
   These data correlated  cumulative
 loadings of solid waste in the soil to
 plant uptakes of cadmium in
. representative leafy vegetables. From
 existing data comparing uptakes of leafy
 vegetables to other basic food classes,
 EPA calculated the ratio of uptakes in
                                        leafv vegetables to those in other
                                        classes The ratios were then «pplicd to
                                        the field data to predict what uptakes
                                        would have been if other types of crops
                                        had been grown on former
                                        landspreading sites. This gave an
                                        estimate of cadmium uptakes that would
                                        be likely to occur in fields with differing
                                        cumulative levels of cadmium.
                                          EPA then used a "diet scenario"
                                        analysis to translate the plant uptake
                                        levels into predictions about the amount
                                        of cadmium entering the human food
                                        chain. The Agency's assumptions about
                                        intake of the various food classes
                                        followed that of the U.S. Food and Drug
                                        Administration's 1974 Total Diet
                                        Studies. From this. EPA calculated the
                                        additional cadmium entering the human
                                        diet, assuming varying levels of
                                        dependence on crops from waste-
                                        amended fields. (EPA calculated intakes
                                        for situations where 100%, 50%, 25% and
                                        10% of the diet come from such fields.)
                                          The 5 kg/ha limit for acid soils (below
                                        6.5 pH) was established  by relating the
                                        diet scenario analysis to the health
                                        effects analysis. The diet scenario
                                        analysis indicated that on mildly acid
                                        soils (pH = 5.8) 5 kg/ha of cadmium only
                                        Increased dietary cadmium by 22 ug/day
                                        (making the assumption  that no more
                                        than 50 percent of one's  vegetable diet is
                                        derived from sludge fields). However, a
                                        cumulative loading of 7 kg/ha on very
                                        acid soils (pH=4.9) increased the
                                        dietary level by 211 ug/day. This
                                        marked increase in dietary cadmium
                                        may be attributed to both the increase in
                                        the cumulative cadmium application
                                        rate from 5 kg/ha to 7 kg/ha and the
                                        drop in pH from 5.8 to 4.9. Such an
                                        increase is far above the acceptable
                                        level in the diet. Therefore, EPA has
                                        established the maximum cumulative
                                        limit at 5 kg/ha for acid soils.
                                          Soil cation exchange capacity was
                                        also utilized in calculating the
                                        permissible loadings for soils with pH of
                                        6.5 or greater. The evidence available to
                                        EPA indicates that CEC  is an important
                                        index of soil factors in limiting uptakes
                                        in high-pH soils. However, in highly
                                        acidic soils, pH becomes the dominant
                                        factor affecting plant uptake.
                                          Soil CEC is an easily measured Index
                                        of those properties, particularly the
                                        nature and content of clay and organic
                                        matter,  that affect the soil's ability to
                                        adsorb  cadmium. High CEC levels mean
                                        that a soil has a  greater capacity to
                                        adsorb cadmium and thus prevent that
                                        cadmium from entering plants'grown in
                                        the soil. Several  studies have
                                        demonstrated the inverse relationship
                                        between CEC and plant uptake of
                                        cadmium.
                                         The proposed cadmium standard
                                        recognized the importance of CEC and
established differing limits depending on
CEC levels in the background soil. The
actual numbers selected were based on
recommendations from recognized
agricultural research groups (including
the North Central Regional Extension
Services and the U.S. Department of
Agriculture). Several commenters
supported the selected levels as
providing adequate protection against
excessive uptake of cadmium.
  Where possible. EPA also used
existing field studies on former
landspreading sites to validate those
recommendations. An application of the
diet scenario analysis to available data
on high-pH soils with mid-range CEC's
supports the conclusion that the levels
established in the recommendations
provide adequate protection to the
public.  As an example, again assuming
that half ofthe vegetable diet comes
from sludge-amended  fields, the data
•how that a cumulative level of 7 kg/ha
could result in an 11.9 ug/day dietary
Increment, while a level of 15 kg/ha
could result in a 39.2 ug/day increment
Using the 30 ug/day increment
assumption discussed previously, the 15
kg/ha loading is too high, while the 7
kg/ha loading is well within the
acceptable range. EPA believes that this
analysis supports the selection of 10 kg/
ha is an appropriate standard for soils
with a mid-range CEC. In light of the
other clear evidence of the role of CEC
in limiting uptake EPA believes that it is.
therefore, appropriate to use the limits
recommended by the research
community.
  The Agency recognizes that there are
some facilities with naturally  acid soils
where land management practices can
be implemented with adequate
safeguards to assure that the soil pH
will be  maintained at 6.5 or higher for as
long as  food-chain crops arc grown.
Where such safeguards exist,  the
criteria  provide an option to permit such
facilities to use the CEC-based cadmium
loading rates. However, the Agency is
concerned that the application of up to
20 kg  of cadmium per hectare  may result
in'significant cadmium uptake by crops
if the  pH is not controlled for as long as
food-chain crops are grown. Therefore.
unless the facility can  clearly
demonstrate long-term control over pH,
the Agency strongly recommends that
those facilities having  naturally acid
soils select the option which limits the
cumulative cadmium application rate to
5 kg/ha.
  The Agency considered establishing
even lower cumulative cadmium
application rotes on soils with a natural
pH that  is very highly acidic (including
prohibition on landspreading on soils
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         Federal  Register / Vol. 44. No.  179 / Thursday, September 13, 1979 / Rules and  Regulations   53453
with very low pH). While it is clear that
leafy vegetables, root crops and tobacco
tend to accumulate cadmium in their
tissues and. therefore, are more
sensitive to high soil cadmium
concentrations under acid soil
conditions, insufficient data exist to
establish more restrictive cumulative
levels for such soils. The Agency i3
continuing to examine this situation and
will, upon development of additional
data and information, propose new
cumulative limits for highly acidic soil.  ,
However, in recognition of the higher
uptake of cadmium by these crops, the
Agency recommends avoiding the
application of solid waste containing
cadmium  (e.g., sewage sludge) on very
acidic soils used for the production of
leafy vegetables, root crops and tobacco
and discourages the application to
agricultural land which is likely to be
converted to production of such crops. .
   The Agency also considered requiring
a soilanalysis for total cadmium prior to
the application of solid waste and
adjusting the cumulative  limit for
cadmium additions downward to
account for soils with high background
cadmium concentrations. However, the
Agency was not able to justify the use of
a background correction factor since
there is a paucity of data concerning the
relationship between naturally occurring
cadmium and solid waste-added
cadmium, with respect to crop uptake.
Until these questions are resolved, the
Agency recommends that a soil teat be
performed prior to initiating         ^
landspreading, in order to establish the
background conditions at the site.
Further, for those facilities which have
unusually high background cadmium
soil concentrations, the Agency
recommends  that consideration be g'iven
to reducing cadmium application.
   (d) Annual Cadmium Application
Limit.—Comments received on the
proposed annual cadmium application
limits were widely divergent. Several
commenters stated that the proposed
cadmium  limitation of 0.5 kilogram per
hectare (kg/ha) per year was
unnecessarily restrictive. The indicated
reasons were primarily that the
reduction in solid waste application
would result in increased costs and that
the potential risk to human health  was
not sufficient to justify that reduction. A-
second group of commenters suggested
that the annual limitations on cadmium
application were not sufficiently
protective of public health and should
be reduced much further or the
application of cadmium-containing solid
waste to agricultural lands  be prohibited
altogether, since the proposed limits
would permit the entry of significant
quantities of cadmium into the human
diet.
  Comments were also received on the
proposed cadmium concentration limit
of 25 mg/kg for solid wastes applied to
facilities where tobacco, leafy
vegetables or root crops are grown for
human consumption. Some commenters
viewed the proposed limit as being
overly restrictive, while others
recommended that cultivation of those
crops which tend to accumulate
cadmium to relatively high levels should
not be allowed on waste-amended soils.
  EPA believes that annual cadmium
application limits are particularly
important on those active sites which
are nearing the cumulative cadmium
application limits. As the total amount
of soil cadmium at such sites begins to
reach the cumulative loading limits, both
the cadmium previously applied to  the
soil and new additions of cadmium from
solid waste will affect crop uptake of
cadmium. In setting annual application
rates EPA must account for this factor.
  Available research indicates that
there are significant differences in
•uptake among crop species. It would,
however, be impossible to write specific
cadmium limits for each crop type based
on the available data. Moreover, such
an approach would complicate the
regulation, making implementation
confusing and impractical.
  In looking at individual crop uptakes,
however, EPA determined that there is a
set ofaccumulator" crops which tend
to absorb very large quantities of
cadmium as compared to all other crops.
Tobacco, leafy vegetables and root
crops constitute the "accumulator"
class. In order to provide an adequate
margin of safety EPA believes that the
annual application rates should be
based on data from representative
"accumulator" crops. This assures that
when a mix of crops is grown on sludge-
amended fields no crop will have
dangerous up takes of cadmium.
  The available data indicates that
significant increases of cadmium occur
even with small applications of waste.
For example, annual rates of
approximately 0.7 kg/ha applied to soils
which have not received sludge
previously have been shown to triple the
amount of cadmium in lettuce leaves.
Using the diet scenario analysis it can
te demonstrated that application rates
of 0.8 kg/ha can lead to dietary
increases of 10.3 ug/day from leafy
vegetables alone. Other data indicate
that this level may be even greater
where  cadmium from landspreading in
previous years is already in the soil.
Under these circumstances EPA
concluded that an annual limit of 0.5 kg/
ha is necessary to provide adequate
protection to the public health.
  EPA recognizes that no-t all_crops will
present the same risk as accumulator
crops, particularly in the first few years
of landspreading. However, due to the
factors discussed above, applications of
solid waste should eventually be limited
to 0.5 kg/ha for all food-chain crops.
Therefore, the Agency has decided to
distinguish between accumulator and
non-accumulator crops in the annual
limits. When wastes are applied to
accumulator crops the annual limit will
be 0.5 kg/ha immediately. For all other
crops a phased reduction will be
allowed.
  The criteria limit additions to 2.0 kg/
ha until June 1984 and 1.25 kg/ha until
December 1986. This gives communities
and industry the time necessary to
implement programs, such as cadmium
source control and pretreatment of
industrial discharges, to reduce current
cadmium concentrations in their wastes
or to develop alternative disposal
practices. The schedule has been
slightly relaxed from the proposed
criteria in order to make  it compatible
with the  Agency's pretreatment program
schedule. The Agency believes that
allowing higher cadmium application
rates than 0.5 kg/ha through 1986 will
have a negligible human  health effect
because  the health impacts from-
cadmium are long-term and cumulative
in nature. Based on assumptions similar
to those used in the "diet scenario".
analysis (see the discussion of
cumulative loading limits), it can be
shown that during this initial period
applications of 2.0 kg/ha do not present
significant health risks.
  The proposed regulation also
distinguished between accumulator and
non-accumulator crops, and that
approach is being maintained in the
final criteria. However, the proposed
limit for accumulator crops was
expressed in terms of sludge quality
(cadmium concentration  in the waste
not to exceed 25 mg/kg.dry weight).
Calculations show that a cadmium
concentration limit of 25 mg/kg in the
solid waste will not necessarily preclude
application rates above 0.5 kg/ha, the
level which EPA believes is more
directly related  to the human health risk.
  For example, some solid wastes are
often applied to the land as soil
conditioner or mulch. Such a solid waste
(e.g., composted sewage sludge), at a..
cadmium concentration of 25 mg/kg.
would contribute cadmium to the soil at
the rate of about 1.5 kg/ha when applied
1.3 cm (0.5 inch) thick to the land
surface. Therefore, EPA decided to
integrate this standard with the rest of
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53454   Federal Register  /  Vol.  44, No. 179 / Thursday,  September  13. 1979  / Rules and Regulations
 the section and express the limit in kg/
 ha.
   (e) Closely Controlled Facilities.
 Substantial public comment was
 received on the second major approach
 proposed for controlling dietary intake
 of cadmium via the application of solid
 waste to land. This approach required
 cadmium levels in crops or meats
 produced from solid waste-amended
 soils to be comparable to cadmium
 levels in similar crops or meats
 produced locally  where solid waste had
 not been applied. Several commcnters
 stated that this approach would be very
 difficult to implement because of
 problems in establishing an effective
 system to monitor and control
 egricultural products. Moreover, terms
 such as "local market" and "comparable
 levels" are vague and. therefore, subject
 to varying interpretations.
   Commenters suggested two major
 alternatives to the proposed approach;
 both of these were considered by the
 Agency. They were dilution of cadmium-
 containing crops and meats in the
 market place, and establishment by the
 FDA of maximum permissible levels of
 cadmium in food  products. Dilution in
 the market place  was not selected as a
 control option, partly because of the
 difficulty of implementation. More
 importantly, the dilution of a toxic
 contaminant into the food chain is an
 unacceptable long-term policy because
 it could, over a number of years.
 significantly increase the total body
 burden in humans.
   The FDA indicated that the
 alternative approach of establishing a
 tolerance level for cadmium in food
 products is not possible at this time
 because of insufficient data. A
 nationwide survey is being conducted
 currently by the EPA. FDA. and USDA
 on cadmium levels in raw agricultural
 commodities: however, several years
 will  be required to obtain the
 statistically meaningful data necessary
 to establish tolerance levels in
 agricultural crops.
   Based on the public comments
 received, the proposed criteria have
 been modified to simplify
 implementation yet still provide
 adequate health protection. As
 promulgated, this  cadmium  management
 approach sets forth four requirements
 which will serve to minimize the
 increase of cadmium in the human food
 chain.
  First, only animal feed may be grown
 under this option.  Research  data show
 that animals excrete most of the
 Ingested cadmium: the small amount
 that is absorbed is accumulated in
viscera such as the kidney and the liver.
The likelihood of significantly increasing
individual or x^ncral  dietary cadmium
 levels through animal feeds is negligible.
 Several commenters suggested that the
 Agency consider prohibiting the
 marketing of livers and kidneys of such
 animals for human consumption. There
 Is some question whether such an
 approach is within EPA's authority
 under the Act. Moreover, control of
 distribution in this manner is
 unnecessary because the marketing of
 organs from such animals would not
 result in a significant increase of
 cadmium  in an individual's diet.
   The second control to assure proper
 management of the facility is the
 requirement that the solid waste and
 toil mixture have a pH of 6.5 or greater
 at the time of solid waste application or
 at the time the crop is planted.
 whichever occurs later. The Agency
 believes that maintaining the soil pH  at
 a near-neutral level is particularly
 Important under this cadmium
 management approach where the
 cadmium  application rate is
 unrestricted.
   The third requirement calls for the
 development of a facility operating plan.
 The purpose of this plan is to
 demonstrate how the animal feed will '
 be distributed and what safeguards are
 utilized to prevent the crop from
 becoming a direct human food source.
 EPA is primarily concerned about crops
 such as corn, wheat and soybeans
 which may be used for animal feed or
 direct human ingestion. In addition, the
 facility operating plan should describe
 the measures that have been taken to
 safeguard against possible health
 hazards resulting from alternative future
 uses of the land. Some future land uses.
 such as the establishment of vegetable
 farms  or home vegetable gardens, could
 result  in significant dietary increases  of
 cadmium. Such provisions in the facility
 operating  plan could  cover a range of
 options, such as dedication of the
 facility as a public park, placement of
 fresh top soil over the site, or removal of
 the contaminated soil.
  The  fourth requirement is a stipulation
 In the land record or properly deed
 which  states that the property has
 received solid waste at high cadmium
 application rates and that foodchain
 crops should not be grown, due to a
 possible health hazard.
  (2) Poly-chlorinated Biphenyls
(PCB's). The proposed criteria required
 that  solid waste containing pesticides
and persistent organics, when applied to
land used  for the production of food-
chain crops, not result in levels of these
substances in excess of the tolerances
set pursuant to the authorities of the
Federal Food, Drug and Cosmetic Act.
The proposed criteria also required that
solid waste of concern due to its toxic
organic chemical or heavy metal content
 (e.g., PCBs and lead) not be applied to a
 site so that the freshly applied solid
 waste may be directly ingested by
 animals raised for milk or by humans,
   At this time, EPA has decided not to
 establish tolerances for pesticides and
 persistant  organics  in solid waste. They
 were not developed because there were
 no adequate data on the amounts of
 these substances in solid waste to
 demonstrate a public health risk.  An
 or.xoing study is expected to obtain
 Information on the  amount of pesticides
 and persistent organics In sewage
 sludge to help develop a standard
 relating to this subject. After reviewing
 existing FDA tolerance limits for such
 fubstances. EPA has determined that
 they are impractical as a basis for
 standards  for  solid  waste application to
 food-chain lands, because those
 tolerance limits are based on food
 contamination from pesticide
 application. At this  time there is almost
 no information available indicating  the
 relationship between the level of such
 substances in  solid  waste and the
 resulting food contamination. Direct
 application of the FDA tolerance limits
 would require extensive chemical
 analysis for a  very large number of
 pesticides  and toxic organic substances
 that might  be present in the solid waste
 in trace amounts. Other data source.-
 also did not provide an adequate basis
 for setting  standards. The Agency will
 continue to evaluate data on this subject
 and explore this problem with the FDA
 and other interested parties. It is
 possible that standards on this subject
 could be part of pending sewage sludge
 disposal guidelines  under Section 405 of
 the Clean Water Act. as well as future
 amendments to the criteria.
  While EPA is concerned about the
 health problem posed by ingestion of
 lead, the Agency is not aware of any
 evidence that increased lead ingestion
 by dairy animals results in elevated lead
 levels in milk.  Consequently, the Agency
 is not able  to promulgate a standard for
 lead based on  ingestion of solid waste
 by dairy animals, as was suggested by
 some commenters. While direct
 ingestion of lead by  children, which  may
 occur when they play in areas where
 sludge has  been applied, may also be a
 concern, there  is limited data available
 to establish a standard for this situation.
The Agency intends to explore this
potential problem further in the pending
sewage sludge disposal guidelines under
Section 405 of the Clean Water Act.
  In establishing the standard for PCB's.
the Agency looked to tolerance levels
established by the FDA to define the
health risk. The FDA has established
maximum tolerance  levels of 0.2 mg/kg
(actual weight) for animal feeds and  1.5
mg/kg (fat basis) for milk. The standard
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         Federal  Register / Vol.  44, No. 179 / Thursday,  September 13,  1979 / Rules and  Regulations   53455
promulgated in the criteria is designed
to prevent PCS levels from exceeding
these levels due to application of solid
waste to fields growing animal feed.
When solid wastes are applied to the
land surface so as  to allow direct
contact between the solid waste and the
crop, the animal feed can become
contaminated. By incorporation of the
solid waste beneath the soil surface
(generally below the root zone of
pasture grasses), the amount of ingested
PCB's is greatly reduced. Therefore, EPA
has concluded that the proper regulatory
strategy is  to require incorporation of
the solid waste into the soil when the
PCS level in the waste materiaHs so
high that direct contact between  the
crop and the  soil could cause the FDA
tolerances to be violated.
  Based on assumptions recommended
by FDA, EPA calculated the
concentration level of PCB's in solid
waste which might cause the FDA
tolerances to be'violated. These
calculations established the PCB
concentration threshold at 10 mg/kg.
Generally, then, any sludge which
exceeds that level of PCB's must be
incorporated into the soil when applied
to4and used for the production of food-
chain crops.
  • There is, however, one exception to
that requirement. Wastes which exceed
10 mg/kg of PCB's may be applied to
fields without incorporation if testing of
the animal feed grown on the field
demonstrates that the FDA standards
will not be violated. If such testing
indicates that the FDA standards have
been violated, then the solid waste
disposal activities leading to the    /
contamination have violated the  criteria.
  It should be noted that the calculation
of the 10 mg/kg level for PCB levels in
the waste is based on the assumption
that the only  way PCB's enter a grazing
animal is through the adherence of
waste material to the vegetation eaten.
EPA recognizes that a certain amount of
PCB's may enter the animal due to direct
ingestion of soil. At this time, however,
EPA does not have sufficient data to
know how that factor  should be used in
the analysis. Moreover, the
recommendations from FDA did not
take that factor into consideration.
  As discussed earlier this portion of
the regulation is being issued as "interim
final", which  means that further public
comment is solicited. EPA encourages
the public to provide suggestions and
data that would help the Agency to
account for the direct ingestion of soil in
setting a PCB standard.
I. Disease (Section 257.3-6)
  Solid wastes can contain pathogenic
bacteria, viruses and parasites which
can infect both humans and animals.
Wastes can provide food and harborage
for rodents and flies which are capable
of transmitting these disease organisms
to humans and animals. Other routes of
disease transmission to humans and
animals include direct contact with
wastes during landspreading operations,
contact with soil or plants which have
been contaminated with wastes, or
ingestion of food and water-
contaminated with wastes.
  The proposed criteria required
protection of public health by control of
disease vectors. This requirement was
to be met through minimizing the
availability of food and harborage for
disease vectors or through other
techniques where appropriate.  In
another section, the proposed.criteria
required  stabilization of solid waste of
concern due to its pathogen content
when applied directly  to the surface of
land used for the production of food-
chain crops. In addition, a one-year
waiting period was. prescribed  before
growing human food crops which are
normally eaten raw. In yet another
section, the proposed criteria required
controlled access to solid waste
disposal facilities so as to minimize  '
exposure of the public to exposed waste.
  The final disease criterion combines
provisions concerning vectors and
pathogens. The provision concerning
vectors calls  for the minimization of on-
site populations of disease vectors.
Periodic application of cover material
(usually at the end of each operating
day) or other appropriate techniques
should satisfy the performance
standard.
  Sewage sludge and septic tank
pumpings are the solid  wastes which are
generally applied to the surface of.the
land and are  of concern due to  their
pathogen content. To protect "public
health, the criteria provide for control of
pathogens in  disposal of these wastes
by one of several operational
approaches as described below.
  Sewage1 sludge applied to the land.
surface or incorporated into the soil
must be treated by a Process to
Significantly Reduce-Pathogens. Aerobic
digestion, air drying, anaerobic
digestion, composting, lime stabilization.
or other similar techniques will satisfy
this requirement. In addition, public
access to the  site must be controlled for
at least 12 months, and grazing by
animals whose products are consumed
by humans must be prevented for at
least one month.
  Septic tank pumpings must be treated
by one of the  Processes to Significantly
Reduce Pathogens, unless public access
to the facility is controlled for at least 12
months and grazing by animals whose
 products are consumed by humans is
 prevented for at least one month.
 Neither set of provisions for sewage
 sludge or septic tank pumpings apply
 where these wastes are disposed of by a
 trenching or-burial operation.
   Further public health protection is
 required when sewage sludge or septic
 tank pumpings are applied to land
 where crops for direct human
 consumption are grown less than 18
 months after waste application. In these
 instances, the waste material must be
 treated, prior to application, by a
' Process to Further Reduce Pathogens.
 Beta ray irradiation, gamma ray
 irradiation, pasteurization or other
 equivalent methods will satisfy this
 requirement if performed after a Process-
 to Significantly Reduce Pathogens. High-
 temperature composting, heat drying,
 heat treatment and thermophilic aerobic
 digestion will satisfy this requirement
 without prior treatment. A Process to
 Further Reduce Pathogens is not
 required if there is no contact between
 the solid waste and the edible portion of
 the crop, as long as the solid waste is
 treated by a Process to Signficantly
 Reduce Pathogens prior to application.
 In addition, public access to the facility
 must be controlled for at least 12 months
 after solid waste application, an:
 grazing of animals vvi'iose products are
 consumed by humane must be pi-evented
 for at least one month.
   Uke the portion of the criteria .
 concerning application of solid waste to
 food-chain crops (§ 257.3-4), the sewage
 sludge and septic  tank pumpings
 provisions of the disease section are
 being issued as an "interim final"
-regulation. While  there was extensive
 public review and comment on the
 proposed regulation, the public has not
 had a full opportunity to examine and
 analyze the new data and technical
 support for this section. At the same
 time EPA believes that it must
 promulgate this portion of the regulation .
 in order fo satisfy the spirit of the court
 order mandating issuance of the criteria.
 EPA will fully review all comments and
 make changes in the regulation if such
 modifications are  warranted by the
 data.
   (1) Disease Vectors. Some
 commenters sought a more specific
 statement of the performance objective
 of this provision. EPA explored the
 possibility of developing a numerical-
 performance objective, but determined
 that such a standard would not be
 meaningful. While the  risk from disease
 vectors is very real, the risk cannot be
 translated into a measure of "rats per
 square meter" or "flies per cubic foot of
 air space." Moreover, such performance
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53456   Federal Register  /  Vol. 44,  No. 179  /. Thursday. September 13. 1979  /  Rules and Regulations
standards could not be measured with
any accuracy. Therefore. EPA made the
standard more specific by requiring
minimization of on-site populations of
disease vectors. This statement of the
standard leaves no question that the
facility must not be a breeding ground,
habitat or feeding area for vector
populations. At  the same time, it
provides some flexibility in the
implementation of the standard.
   Several commenters indicated that,
since there are a number of techniques
to protect public health from disease
vectors, the phrase "minimizing the
availability of food and harborage for
vectors through periodic application of
cover material" should be deleted. EPA
agrees and has done so.
   At most facilities which dispose of
putrescible  wastes, the  most effective
means to control rodents is the
 application of cover material at the end
•of each operating day. Other means
 include composting or processing the
.waste, so as to render it unattractive to
rodents, or using rodenticides. At some
facilities, disease vectors such as flies
 may be more difficult to control than
 rodents: but certain practices, such as
 the periodic application of cover
 material, can help alleviate the
 problems. Mosquitoes can be controlled
 by eliminating stagnant water for
breeding, by predatory or reproductive
 control and. if necessary, by spraying
 with insecticides or repellants.
   Cover material also serves other
 purposes: (a)  It helps contain odor, litter,
 and air emissions, thereby improving the
facility's aesthetic quality; (b) it reduces
 the potential for fires: (c) it reduces
 rainwater infiltration, thereby
 decreasing leachate generate • and
surface and ground-water
contamination: and (d) it improves ...e
facility's appearance and enhances
 utilization after completion.
   Since periodic application of cover
material is an effective, widely used and
generally preferred means of controlling
vectors. EPA believes that it is
appropriate to specify it in the criteria. It
is impractical, however, to cover some
wastes. Moreover, cover material is not
generally necessary for wastes which
are non-putrescible. relatively stable or
inert. The criteria allow for other
techniques lo be employed in these
situations.
   EPA has not included the phrase
"minimizing the availability of food and
harborage" in the final standard. That
language would  not cover such control
measures as repellants,  insecticides and
rodenticides. which could be effective in
meeting the  objective of this section.
   Commenters also requested a
definition of the  term "disease vector."
Disease vectors are rodents, flies and
mosquitoes, since these are the known
organisms common at disposal facilities
that are capable of transmitting disease.
  (2) Sewage SJudge and Septic Tank
Pumpings.In establishing regulations to
protect public health from pathogen-
induced disease, it must be  recognized
that there is a distinction between being
exposed to disease-producung
organisms and actually acquiring a
disease. Healthy humans and animals
can tolerate small numbers of
pathogenic organisms without acquiring
a disease. Disease normally occurs
when the body's immune system  is
impaired, or the dose of pathogens is so
great that it overwhelms the body's
defense mechanism. In setting these
criteria, the goal is to prevent human
exposure to large numbers of pathogenic
organisms due to solid waste disposal '
activities.
  Commenters requested specification
of which solid'wastes are of concern
due to their pathogen content. The
criteria  have been modified to specify
sewage sludge and septic tank pumpings
as the wastes which are generally
applied to the surface of the land and
are of concern due to their pathogen
content. Although little information is
available on septic tank pumpings. the
relatively long residence time of the bulk
of the waste material in a septic tank
should reduce the density of pathogenic
organisms. Therefore, the Agency has
tentatively concluded that septic tank
pumpings have the same general
characteristics with regard to land
application as partially treated
municipal sewage sludge. The public is
invited to submit pertinent data on this
subject: the  Agency will review any new
information and reassess these
regulations accordingly.
  Sewage sludge and septic tank
pumpings contain various types of
pathogenic bacteria, viruses and
parasites. While bacteria are greatly
reduced by sunlight and drying, viruses
may persist  in soils and on vegetation
for several weeks or months. Parasitic
ova and cysts are quite resistant to
disinfectants and adverse
environmental conditions. Many, in fact,
require a period of free-living existence
In the soil before becoming infectious to
man. Therefore, a major reason for
requiring the control of pathogens is the
potential for human ingestion of soil or
plants contaminated with such wastes
containing ova or cysts.
  Some  commenters suggested that the
criteria require a "pathogen-free"
sewage sludge. EPA does not believe
that such regulation is necessary to
avoid a reasonable probability of
adverse effects on the population that
may come in contact with sludge-
amended fields. A greater degree of
protection is needed for certain solid
waste disposal practices  (i.e.,
application to land where food-chain
crops are grown), and this section
provides for such protection.
  The proposed regulation relied on
stabilization as the principal treatment
technique to reduce the risk of pathogen-
Induced disease. However, because the
term "stabilization" conventionally
related to odor control and to a lesser
degree pathogen reduction, this term is
no longer used in the criteria. The
criteria have been revised to require
that sewage sludge and. under certain
conditions, septic tank punpings be
treated by a Process to Significantly
Reduce Pathogens. These processes
include aerobic digestion, air drying,
anaerobic digestion, composting (three
techniques), lime stabilization or other
equivalent techniques.
  EPA recognizes that not all of these
processes achieve exactly the same
level of pathogen reduction. Variations
In weather, residence times.
temperatures and other factors will
Influence the effectiveness of each
process. The Agency also recognizes
that different processes may be more or
less effective in destroying certain types
of pathogens (i.e.. bacteria, viruses or
parasites). Each process,  however, has
been shown to achieve a  significant
reduction in pathogen levels. Therefore,
EPA believes that they are appropriate
to achieve the objectives  of this section.
  The proposed regulation required
controlled access to disposal facilities
so as to minimize exposure of the public
to hazards posed by exposed waste. The
Final regulation seeks to minimize
exposure of the public to  pathogens in
the upper layers of waste-amended
soils. Since pathogens in  the surface soil
are generally reduced to insignificant
levels within 12 months of application.
the criteria require that public access to
the facility be controlled for that period
of time. "Controlled" does not mean that
all entry on the site be precluded. The
term "controlled." rather  than   '
"prevented." was chosen for regulating
public access, because with proper
precautions  there appears to be no
health hazard. However,  there would be
a health hazard if, for example, children
were permitted to ploy on the waste-
amended soil. Therefore,  fencing would
be necessary if these wastes were
applied to areas frequented by the
general public (e.g., park lands) but
fencing would not be necessary on farm
land which was not  available for use by
the public.
  This section also includes a limit on
animal access to the  fields for grazing
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         Federal  Register / Vol.  44, No. 179  /  Thursday, September 13,  1979 / Rules and Regulations   53457
for one month after sewage sludge is
applied. This is appropriate for several
reasons. First, the animal acts as a first
line of defense against human contact
with pathogens. The products derived
from the animal (meat or milk) will not
contain the same level of pathogens as
might enter the animal due to grazing on
waste-amended fields. Second, in many
cases rainfall in the one-month period
after application will wash the sludge
off the crop. Third, available evide'nce
indicates that where sludge does remain
on the crop, a one-month period should
be sufficient for natural weather
conditions (e.g., sunshine, wind) to
destroy most pathogenic organisms.
  The access restrictions described
above are required for all facilities
receiving sewage sludge,- even after the
waste has been treated  by a Process  to
Significantly Reduce Pathogens. For
septic tank pumpings, the access
restrictions  may be used as an
alternative to such a Process. This is  due
to the fact that containment in a septic
tank will result in partial pathogen
reduction in the waste and should
diminish its attractant potential to
disease vectors such as flies and
mosquitoes. However, septic tank
pumpings do not undergo the kind of
pathogen destruction that can occur
with anaerobic digestion, because the
waste is being continually reinoculated
with fresh waste material. Therefore,
EPA concluded that such wastes should
be treated with a Process t'o
Significantly Reduce Pathogens or be
subject to the access restrictions.
   As indicated earlier, special treatment
is necessary for food-chain crop
cultivation,  where the risk of direct
human consumption of crops
contaminated by pathogens is higher. To
provide protection, the proposed
regulation relied on a one-year waiting
period between waste application and
use of that land for food-chain crops.
The regulation now calls for the use of a
Process to Further Reduce Pathogens if
crops for direct human consumption are
grown within 18 months of application
or incorporation of the sewage sludge or
septic tank pumpings. If no such crops
are grown within 18 months of
application, treatment by a Process to
Further Reduce Pathogens is not
required.
  The processes chosen should
essentially destroy all bacteria and
viruses and greatly reduce the number
of parasites  in the waste material. Two
sets of processes are permitted—those
which are sufficient in themselves and
those which must follow a Process to
Significantly Reduce Pathogens in order
to be effective. Processes which are
 adequate in themselves are high-
• temperature composting, heat.drying,
 heat treatment and theromophilic
 aerobic digestion. Processes which must
 follow a Process to Significantly Reduce
 Pathogens are beta ray irradiation,
 gamma ray irradiation and
 pasteurization. This sequence of
 processes is necessary to assure that the
 waste is not an attractant to vectors.
 Irradiation or pasteurization, while
 effective against pathogens, do not
 provide the volatile solids reduction
 necessary to prevent a vector problem.
   Based on available data, the Agency
 concluded that a Process to Further
 Reduce Pathogens is not necessary
 when there is an 18-month interval
 between land application of solid waste
 and the growing of crops for direct
 human consumption. EPA recognizes
 that there is some uncertainty about the
 life expectancy of pathogens in wastes
 applied to croplands. Bacteria and
 viruses persist for only a few months,
 but parasites, particularly resistant
 species such as Ascaris lumbricoides,
 may last much longer. Reports range
 from "no survivors" after a few months
 to "some survivors" (not necessarily
 viable) after ten years for such
 organisms.
   Survival is most likely in the soil
 below the top five centimeters of soil.
 Field conditions such as sunlight,
 desiccation, freezing, heat and freeze-
 thaw cycles are effective at reducing
 survival times in the upper layer of the
 soil. EPA selected the 18-month period
 because within that period most of the
 waste-amended soil will be exposed to
 the hostile environment found at the soil
 surface. Agricultural soils are typically
 plowed, or cultivated at least annually.
 Thus, an 18-month waiting period
 assures that soil which was previously
 below the surface will be exposed to the
 harsh surface conditions for at least six
 months before planting. The growing
 period will provide additional exposure.
 of the pathogens before harvest. EPA
 believes that this will provide a
 reasonable probability that pathogen
 levels will be greatly reduced. Since this
 is an "interim final" regulation, EPA
 encourages public comment on the
 appropriateness of this rationale.
   EPA recognizes that for some crops
 (e.g., citrus fruits, corn) the edible
 portions are not exposed to. nor are
 likely to come in contact with, the
 sewage sludge or septic tank pumpings.
 Therefore, there is no need to use a
 Process to Further Reduce Pathogens
 when such a crop is grown. However, in
 this case the waste must be treated by a
 Process to Significantly Reduce
 Pathogens, public access to the facility
must be controlled for at least 12
months, and the grazing of animals
prevented for at least one month after
application of the waste. The Agency
chose the more conservative approach
of requiring significant pathogen
reduction and controlled access for both
sewage sludge and septic tank pumpings
because even where direct contact
appears unlikely, the quality of crops
which are directly consumed by man
must be assured.
  In examining the health risk presented
by pathogens, EPA determined that
pathogens are not likely to migrate in
the soil. Pathogens tend to remain.
intimately associated with the waste
material and are often too large to move
through soil pore systems. Also, soils
have been reported to be effective in
removing viruses and bacteria from
water. Surface erosion with the resultant
water runoff seems to be the only route
for movement of pathogens. Based on
these findings, the Agency concluded
that sewage sludge and septic tank
pumpings that are placed underground
by a trenching or burial operation
should not be subject to  this section.
Under such circumstances there will be
minimal movement of the organisms
through the soil,  and the risk of erosion
is slight because the wastes are
completely covered.
/. Air'(Section 257.3-7}
  Open burning is the uncontrolled or
unconfined combustion of solid wastes.
Open burning is  a potential health
hazard, can cause property damages,
and can be a threat to public safety.
Smoke from open burning can reduce
aircraft and automobile visibility and
has been linked to automobile accidents
and death on expressways. The air
emissions associated with open burning
are much higher  than those associated
with incinerators equipped with air
pollution control devices.
  The proposed criteria provided for.
control of air emissions through three
stipulations: First, the facility was to
control air emissions so as to comply
with Federal, State, and local air
regulations. Second, all open burning of
residential, commercial,  institutional,
and industrial solid wastes was
prohibited. Third, open burning of other
solid wastes could be permitted if in
compliance with State and local air
regulations.
  This finafair criterion has two
components. First, there  shall  be no
open burning of residential, commercial,
institutional or industrial solid waste.
(This provision does not apply to
infrequent burning of agricultural
wastes, silvicultural wastes, land-
clearing debris, diseased trees, debris
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53458   Federal Register  / Vol. 44.  No. 179  / Thursday. September 13. 1979  /  Rules and Regulations
from emergency clean-up operations and
ordnance.) Second, air emissions caused
by solid waste disposal activities shall
not violate applicable requirements
developed for Slate implementation
plans (SIP's) under Section 110 of the
Clean Air Act.
   While several commenters suggested
that a ban on open burning is
unnecessary. EPA has decided to retain
that provision for residential.
commercial, institutional or industrial
waste. The ongoing open burning of
these wastes presents significant
hazards to human health, and no health
or environmental benefit is derived from
 the practice. Several commenters
 suggested allowing open burning with a
 variance. There is no environmental
 rationale for such a variance because
 open burning does not lessen the need
 for disease vector control or leachate
 control for maintaining surface and
 ground-water quality. Moreover,
 variance procedures for this situation
 would be particularly difficult to
 administer because of the dynamic
 nature of the many variables involved
 (existing air quality, wind speed.
 humidity, mixing and vertical
 dispersion, efficiency of the bum,
 amount and type of waste, etc.}.
   EPA decided to exempt from the open
 burning prohibition those wastes which
 are typically burned infrequently. The
 burning of agricultural wastes in the
 field, land-clearing debris, standing
 trees in a forest,  diseased trees, debris
 from emergency  clean-up operations and
 ordnance is not typically an ongoing
 practice and. thus, does not present a
 significant environmental risk. In
 addition some of these practices,
 particularly the destruction of disease-
 carrying trees or debris from emergency •
 clean-up operations, provides an added
 environmental benefit in preventing
 chances of disease or accident. It should
 be noted, however, that the criteria
 assure that the conduct of these
 infrequent acts of burning must be  in
 compliance with applicable
requirements developed under the  Slate
SIP.
   In requiring compliance with the SIP.
EPA is seeking to coordinate the criteria
with the Clean Air Act, as mandated in
Section 1000 of the Act. The regional
health concerns addressed  through the
SIP's are clearly of concern under the
Act as well. The  prohibition of open
burning should prevent most air quality
problems. Where such concerns are not
covered  by the open burning ban, EPA
believes that it is unacceptable for  solid
waste disposal activities lo cause
violations of SIP requirements.
   EPA has eliminated that part of the
proposed regulation that required
compliance with "all applicable Federal,
State and local air regulations" and the
reference to protection of public health
and welfare. Some commenlers said that
the proposed criteria "federalized" Slate
and local air regulations. EPA is not
federalizing any such regulations in the
final criteria. In tying the criteria to the
SIP's, EPA is assuring that, at a
minimum, solid waste activities that
undermine Congressionally-established
Federal environmental air quality
objectives will not be considered
adequate under the Act.
  Several commenlers requested
clarification regarding the impact of the
criteria on the use of pit or trench
Incinerators. Emission factors (i.e..
participates) for such incinerators equal
or exceed those for open burning dumps.
Since such devices do not control
emissions, they fit the definition of open
burning. Thus, for purposes of the
criteria, combustion in a trench
incinerator constitutes "open dumping."
  Comments were requested in the
Preamble of the proposed regulation on
the advisability of including in the final
promulgation specific air quality limits
which would be based on Occupational
Safety and Health Administration
(OSHA) air quality standards. Several
commenlers noted that since OSHA air
quality standards are based on
workplace exposure  and not ambient air
quality, the inclusion of these standards
would be inappropriate and possibly
confusing. Air quality standards based
on OSHA regulations have not been
included in the final promulgation.
  Commenters also suggested that the
content of the  air criteria be moved to
the safety criteria (§  257.3-fl) since many
of the dangers of open burning relate
directly lo public safety. The Agency
considers the problems of open burning
to be broader than just public safety,
thus, this change was not made.
However, the safely criteria have been
revised to reference the air criteria.

K. Safety (Section 257.3-3)
  This portion of the  criteria addresses
a set of adverse effects involving
potential accidents which could  be
caused by solid waste disposal
activities. The  legislative history of the
Act indicates that in passing the
provisions authorizing these criteria  the
Congress was concerned about all of the
effects addressed in this section. The
safety hazards addressed in the final
regulation include explosive gases, fires,
bird hazards to aircraft and public
exposure lo wastes due to  uncontrolled
access to disposal sites.
  The proposed regulation also
contained a provision for toxic and
asphyxiating gases. While EPA is quite
concerned about the emission of such
gases from solid waste. EPA was unable
to identify sufficient information on the
nature of this problem to support the
setting of particular standards. The
existing data on the generation of toxic
and asphyxiating gases in solid waste is
quite limited. In particular, it is difficult
to define a set of gases generated in
(olid waste disposal that present a
public health hazard. Even if such a set
of gases could be identified it it difficult
to determine, on the basis of data
currently available to EPA. what levels
of such gases may be tolerated without
a substantial risk lo public health or the
environment. EPA will continue  to
explore this problem. However, at
present there is insufficient information
to support particular limits on toxic and
asphyxiating gases.
  (1) Explosive gases. Solid  waste
disposal activities may produce
explosive gases. In particular, methane
gas is a product of solid waste
decomposition. The accumulation of a
sufficient concentration of methane gas
in disposal facility structures or nearby
off-site structures may pose  a serious
threat to the health and welfare of
facility employees, users of the disposal
site, and occupants of nearby structures.
Explosions resulting in injury and death
have been caused by gases from solid
waste disposal.
  The proposed criteria  required that
the concentration of explosive gases in
facility structures and in soil at  the
facility property boundary not reach the
lower explosive limits (LEL) for the
gases. The final regulation is essentially
the same except that concentrations in
facility structures will not be allowed to
exceed 25 percent of the lower explosive
limit for the gas. In addition  the final
standard, which could potentially be
applicable to several explosive gases.
will only be concerned with  methane at
this time.
  Commenlers suggested  that the gas
criteria be deleted and that control be
left to the Occupational Safety and
Health Administration (OSHA).
Following consultation with  OSHA, the
Agency rejected this suggestion because
the jurisdiction of OSHA does not
include all solid waste disposal  facilities
and practices of concern to the Act. nor
docs it include off-site residences to
which gases can migrate.
  The Agency has decided to adjust the
standard for facility structures to
provide a margin of safety. Several
commenlers suggested such a change,
since allowing explosive gas to
accumulate in concentrations just under
the lower explosive limit would  be
extremely dangerous and would not
provide for a reasonable probability of
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         Federal Register  /  Vol. 44. No.  179 / Thursday.  September  13.  1979 / Rules and Regulations   53439
avoiding adverse effects. In selecting the
25% figure EPA is using a safety factor
recognized by other Federal agencies as
being appropriate for similar situations.
  EPA also concluded that such a safety
factor was unnecessary at the property
boundary. Gases at or below the LEL at
the property boundary will necessarily
become somewhat diffused before
passing into a structure  beyond the
properly boundary. Thus, in assuring
that the LEL is not exceeded at the
boundary EPA has provided a margin of
safety against an off-site explosion.
  EPA has selected methane as the
single gas of concern. The information
available to EPA indicates that build up
of methane gas has been the principal
source of explosions associated with
solid waste disposal. Other gases may
be added to the list as new information
develops.
  Commenters recommended that
disposal facilities not in close proximity
to off-site structures be  exempted from
the gas criteria.  Considering that gas
production in disposal facilities is a
long-term process continuing for
decades, the Agency rejected this
recommendation. Facilities which are
remote today may be surrounded by
extensive development  in the future,
especially after  completion of disposal
operations.
  (2) Fires. Fires at solid waste disposal
facilities pose the threat of property   •
damage and injury or death to facility
employees, users, and nearby residents.
Examples of circumstances which can
lead to fires associated  with disposal
facilities or practices are: Vandalism,
carelessness,  spontaneous combustion,
open burning  of wastes, and disposal of
hot ashes.
  The proposed criteria required that all
fires be extinguished expeditiously and
that fire hazards be minimized through
proper site construction and design and
periodic application of cover material
where appropriate.
  According to the final regulation, the
facility or practice shall not pose a
hazard to the safety of persons or
property from fires. This objective can
be served by compliance with the air
criterion (§ 257.3-7), particularly the
open burning ban. and through periodic
application of cover material.
  Commenters objected to the vague
nature of this provision  as originally
proposed. While some level of flexibility
is necessary, EPA has tried to make this
standard as specific as possible. The
reference to "expeditious" extinguishing
of fires was eliminated.  EPA also
specified types of operational practices
to accomplish the goals  of this section.
  Commenters suggested that, due to the
relationship between open burning and
potential fire hazards, the prohibition on
open burning be incorporated into this
section. As explained previously the
safety criteria  now reference the air
criterion (which contains the prohibition
of open burning.)
  (3) Bird Hazards. Many reports and
investigations show that disposal
facilities and practices involving
putrescible wastes often attract birds, in
spite of vector control efforts
(compaction and cover of wastes, etc.).
When solid wastes are disposed in the
vicinity of airports, the birds attracted to
the area can present a significant risk of
accidents due to collisions between
birds and planes. The Federal Aviation
Administration (FAA) has issued FAA
Order 5200.5, "FAA Guidance
Concerning Sanitary Landfills on or
Near Airports" (October 16, 1974). The
order states that solid waste disposal
facilities have been found by study and
observation to be artificial attractants of
birds and, therefore, "may be
incompatible with safe flight
operations" when located in the vicinity
of an airport.
  The proposed criteria required that
disposal facilities not be located within
the two distance limits (10,000 feet for
turbojets and 5,000 feet for piston-type
aircraft) specified in FAA Order 5200.5
unless the facility was found  to not pose
a bird hazard  to aircraft. For facilities
beyond the specified distances, but
within the conical surface described by
FAA Regulations (FAR), Part 77,
facilities were to be reviewed on a case-
by-case basis  for a potential bird
hazard.
  The final regulation retains the basic
approach but clarifies severs! terms,
including "airport" and "bird hazard."
The provision  for case-by-case analysis
of facilities within the conical surface
has been dropped.
  Some commenters questioned whether
the Act provides authority to  control'
solid waste disposal on the basis of bird
hazards to aircraft. They claimed that
the FAA has adequate authority to
prevent bird hazards to  aircraft,
concluding that this section of the
criteria is not necessary. -
  The criteria  are required to address
the prevention of adverse effects on
health and the environment from solid
waste disposal facilities. The  legislative
history (H.R. Rep. No. 94-1491) cites an
aircraft crash resulting from birds
attracted to a disposal facility as one
example of adverse effects of open
dumps. There are also many other
examples of.such hazards from disposal
facilities. Therefore, the Agency has
concluded that this issue is clearly
within the scope of this regulation.
  Although the FAA is authorized to
control airport operations to reduce bird
hazards to aircraft, its authority does
not extend to disposal facilities outside
airport boundaries which may pose such
hazards. It should be noted, however,
that EPA is not "enforcing" the FAA
order. The selection of the distances
specified in that order is merely a
recognition that they represent a
reasonable determination of the danger
zone around an airport. Likewise, it
should be made clear that neither this
regulation nor the proposed standard
prohibited the disposal of solid waste
within the specified distances. Instead,
the distances define a "danger zone"
within which particular care must be
taken to assure that no bird hazard
arises.
  Some commenters challenged the
relevancy of the 10,000 foot (for
turbojets) and 5,000 foot (for piston-type
aircraft) distances for defining the
danger zone for bird/aircraft collisions.
The distances cited were derived from
FAA Order 5200.5. The distances are
based on the consideration that over 62
percent of all bird strikes occur below
altitudes of 500 feet (150 meters), and
that aircraft are generally below this
altitude within the distances specified.
  Some commenters emphasized that
bird strikes do occur outside the
distances established in the regulation.
Consultation with FAA personnel and
other experts in the field of bird/'aircraft
hazards has revealed that, even when
disposal facilities are located beyond
the distances specified, hazards can
exist where an airport is situated
between a disposal facility and bird
feeding, roosting,  or watering sites. The
hazard arises as birds traverse the
airport in flying between the disposal
facility and watering, feeding or roosting
areas.  However, EPA does not have
sufficient information to indicate how
serious this problem is. Moreover, the
available data is insufficient to support
the setting of national regulations to
cover such contingencies. At some point
it becomes difficult to isolate the
independent effect of solid waste
disposal activities on the bird hazard
problem.
  EPA has also decided to give a clearer
definition of some key terms. The
definition of "Airport" includes those
airfields currently defined by the FAA
as public-use airports. The regulation
applies to that set of airports because
existing data  indicates that the
preponderance of bird strikes occur  at
public-use airports. For example, 120 of
the 121 airports reporting strikes in 1977
were public-use airports, and 220  of the
223 airports reporting strikes In 1978
                                                        295

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 53460
Federal  Register / Vol.  44. No. 179  /  Thursday, September 13.  1979 /  Rules and Regulations
 were public-use airports. The FAA
 agrees with this approach. EPA, in
 consultation with the FAA. may
 broaden the class of airports of concern
 if it receives information demonstrating
 that a similar bird hazard exists at other
 fields.
   In denning the airports of concern
 EPA has also eliminated the proposed
 criteria's reference to "runways planned
 to be used." As several commenters
 pointed out. such a reference would not
 be workable because it would require
 speculation about future siting of
 airports.
   EPA also makes it clear that the "bird
 hazard" of concern is "an increase in the
 likelihood of bird /aircraft collisions."
 Solid waste disposal within the danger
 zone may continue as long  as it can be
 shown that the operation can be
 managed in such a way as  to not
 increase the risk of collision within the
 specified distances.
   After considering public comments.
 EPA has deleted portions of the
 proposed standard. Several commenters
 elated that the use of the conical surface
 in the criteria  was ambiguous and.not
 applicable to this standard. The conical
 surface is an imaginary plane
 delineating an airspace segment 150 feet
 above the established airport elevation.
 The FAA prohibits stationary objects in
 this space because they might interfere
 with approaching and departing aircraft.
 This is inapplicable to solid waste
 disposal activities for two reasons: (1)
 Birds, the "obstructions" of concern in
 this regulation, are hardly stationary;
 and (2] solid waste disposal activities
 are typically low-profile operations
 (below 150 feet) and are  not likely to
 constitute obstructions into the conical
 surface.
   Commcnters asked who was
 responsible for determining whether a
 facility posed a bird hazard to aircraft.
 The Act and the CWA create  the
 implementing mechanisms for these
 criteria. However, in this instance
 consultation with the FAA and the Fish
 and Wildlife Service would be very
 helpful. Furthermore, actions at both the
 airport and the disposal facility can
 reduce or eliminate hazards. Therefore.
 where appropriate this determination
 should be made in consultation with
 these agencies, as well as with the
 owners and operators of the airport of
 concern.
   (4) Access. Materials and  activities
 associated with solid waste disposal
 facilities can cause injury or death to
 persons at the facilities. Potential causes
' of such harm include:
                                 (a) Operation of heavy equipment and
                               haul vehicles:
                                 (b) Hazards associated with the types
                               of waste, including sharp objects.
                               pathogens, and toxic, explosive, or
                               flammable materials; and
                                 (c) Accidental or intentional fires.
                                 The proposed criteria required that
                               entry to the facility be controlled in
                               order to minimize exposure of the  public
                               to hazards of heavy equipment
                               operation and exposed waste.
                                 The final criteria call for control of
                               access to protect the public from on-site
                               exposure to health and safety hazards.
                                 The importance of access control
                               cannot be overstated, since persons
                               have suffered injury and even death at
                               uncontrolled waste disposal facilities.
                               Furthermore, in most cases, there is little
                               economic impact on solid waste
                               disposal operations  in accomplishing
                               •uch control.
                                 During normal operating hours, proper
                               management controls can minimize
                               safety hazards. For example, potential
                               harm to facility operating personnel can
                               be reduced through proper training, use
                               of safety equipment, control of waste
                               types, and other practices. The most
                               effective means of minimizing the risk of
                               injury to other persons is by complete
                               prohibition of access to the site by non-
                               users (e.g. by suitable fencing) and strict
                               control of users while on the site. For
                               individuals disposing of small amounts
                               of wastes, storage or special disposal
                               facilities can be provided at the
                               entrance to the facility or away from the
                               area being utilized by professional solid
                               waste management personnel.
                                 The principal change from the
                               proposed regulation is the broadening of
                               the regulation's coverage. Accidents at
                               •olid waste disposal sites are not limited
                               to hazards caused by heavy equipment
                               operation and exposed waste. EPA
                               believes that particular types of hazards
                               should not be specified in the regulation.
                               thereby allowing for flexibility in how
                               the standard is applied. Therefore,  the
                               criteria seek to avoid public exposure to
                               all potential health and safety hazards
                               at solid waste disposal sites.
                                 Two commenters stated that the
                               proposed requirement for fencing was
                               unreasonable. It should be noted that
                               the Agency did not propose a
                               requirement for fencing. At  many
                               facilities natural barriers exist which
                               make public access very difficult;
                               however, even if the  criteria were
                               complied with through the installation of
                               a fence around the entire property the
                               cost would be relatively insignificant
                               when compared to the other costs
                               required  to properly operate a disposal
                               facility.
 V. Environmental and Economic Impacts
   Voluntary environmental and
 economic impact analyses onthis
 regulation have been performed and are
 presented in the "Final Environmental
 Impact Statement on the Criteria for
 Classification of Solid Waste Disposal *
 Facilities". These analyses are not
 required by the National Environmental
 Policy Act but provide information
 pertinent to the development and use of
 this regulation. Copies of this two-
 volume report may be obtained on
 request from: Solid Waste Information.
 U.S. EPA. 28 West St. Clair. Cincinnati.
 Ohio 45268.
   EPA has also prepared a number of
 background documents that respond to
 public comments not addressed in the
 Preamble. These documents may be
 examined at E.P.A.. 401 M Street. S.W..
 Washington. D.C. 20460 in room 2632. If
 there are apparent inconsistencies
 between  these documents and this
 Preamble, the latter shall represent the
 Agency's position.
   Dated: September 10,1979.
 Douglas M. Co*Ues
 Adminittra'or.

   Title 40 CFR is amended by adding a
 new Part 257 to read as follows:

 PART 257- -CRITERIA FOR
 CLASSIFICATION OF SOLID WAS i E
 DISPOSAL FACILITIES AND
 PRACTICES

 See
 257.1  Scope and purpose.
 257.2  Definitions.
 257 J  Criteria for classification of solid
    waste disposal facilities and practices.
 257.3-1  Floodplains.
 257.3-2  Endangered species.
 257.3-3  Surface water.
 257.3-1  Ground water.
 257.3-5  Application to land used for the
    production of food-chain crops. (Interim
    final).
 257.3-6  Disease.
 257.3-7  Air.
 257.3-a  Safety.
 257.4  Effective dale.
  Authority: Sec.'l006(a)(3J. and sec. 4004(a).
 Pub. L 9*-580. 90 Stat. 2803 and 2815 (42
 U.S.C. 6907(a)(3). 6944); sec, 405(d). Pub. U
 95-217. 91 Slat. 1591.1606 (33 U.S.C 1345).

 $257.1  Scope and purpose.
  (a) These criteria are for use under the
 Resource Conservation and Recovery
 Act (the Act) in determining which solid
 waste disposal facilities and practices
 pose a reasonable probability of adverse
 effects on health or the environment.
  (1) Facilities failing to satisfy these
criteria will be considered open dumps
for purposes of State solid waste
management planning under the Act.
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         Federal Register /  Vol.  44.  No. 179  / Thursday. September 13. 1979  /  Rules and Regulations
                                                                       53461
  (2) Practices failing to satisfy these
criteria constitute cpen dumping, which
is prohibited under Section 4005 of the
Act.
  (b) These criteria also provide
guidelines for sludge utilization and
disposal under Section 405{d) of the
Clean Water Act. as amended. To
comply with Section 405(e) the owner or
operator of any publicly owned
treatment works must not violate these
criteria in the disposal of sludge on the
land.     ,
  (c) These criteria apply  to all solid
waste disposal facilities and practices .
with the following exceptions:
  (1) The criteria do not apply to
agricultural wastes, including manures
and crop residues, returned to the soil as
fertilizers or soil conditioners.
  (2) The criteria do not apply to
overburden resulting from mining
operations intended for return to the
mine site.
  (3) The criteria do not apply to the
land application of domestic sewage or
treated domestic sewage.  The criteria do
apply to disposal of sludges generated
by  treatment of domestic sewage.
  (4) The criteria do not apply to the
location and operation of  septic tanks.
The criteria do, however,  apply to  the
disposal of septic tank pumpings.
  (5) The criteria do not apply to solid
or dissolved materials in irrigation
.return flows.
  (6) The criteria do not apply to
industrial discharges which'a-re point
sources subject to permits under Section
402 of the Clean Water Act, as
amended.
  (7) The criteria do not apply to source,'
special nuclear or byproduct material as
defined by the Atomic Energy Act, as
amended (63 Stat. 923).
  (8) The criteria do not apply to
hazardous waste disposal facilities
which are  subject to regulation under
Subtitle C  of the Act.
  (9) The criteria do not apply to
disposal of solid waste by underground
well injection subject to the regulations
(40 CFR Part 146) for the Underground
Injection Control Program (UICP) under
the Safe Drinking Water Act, as
amended, 42 U.S.C. 3007 et seq.

§ 257.2 . Definitions.
  The definitions set forth in Section
1004 of the Act apply to this Part.
Special definitions of general concern to
this Part are provided below, and
definitions especially pertinent to
particular sections of this  Part are
provided in those sections.
  "Disposal" means the discharge,
deposit, injection, dumping, spilling,
leaking, or placing of any  solid waste or
hazardous  waste into or on any land or
water so that such solid waste or
hazardous waste or any constituent
thereof may enter the environment or be
emitted into the air or discharged into
any waters, including ground waters.
  "Facility" means any land and
appurtenances thereto used for the
disposal of solid wastes.
  "Leachate" means liquid that has
passed through or emerged from solid
waste  and contains soluble, suspended
or miscible materials removed from  such
wastes.  -
  "Open dump'' means a facility for the
disposal of solid waste which does not
comply with this part.
  "Practice" means the act of disposal
of solid waste.
  "Sanitary landfill" means a facility for
the disposal of solid waste which
complies, with this part.
  "Sludge" means any solid, semisolid.
or liquid waste generated from a
municipal,  commercial, or industrial
wastewater treatment plant, water
supply treatment plant, or air pollution
control facility or any other such waste
having similar characteristics and effect
  "Solid waste" means any garbage,
refuse, sludge from a waste treatment
plant,  water supply treatment plant, or
air pollution control facility and other
discarded material, including solid,
liquid, semisolid, or contained gaseous
material resulting from industrial,
commercial, mining, and  agricultural
operations, and from community
activities, but does not include solid or
dissolved materials in irrigation return
flows or industrial discharges which are
point sources subject to permits under
Section 402 of the Federal Water
Pollution Control Act, as  amended (88
Stat. 880), or source, special nuclear, or
byproduct material  as defined by the
Atomic Energy Act of 1954, -as amended
(68 Stat. 923).
  "State" means  any of the several
States, the  District of Columbia, the
Commonwealth of Puerto Rico, the
Virgin Islands, Guam, American Samoa,
and the Commonwealth of the Northern
Mariana Islands.

§ 257.3  Criteria for classification of solid
waste disposal facilities and practices.
  Solid waste disposal facilities or
practices which violate any of the
following criteria pose a reasonable
probability of adverse effects on health
or the environment:

§ 257.3-1 Floodplalns.
  (a) Facilities or practices in
floodplains shall not restrict the flow of
the base flood, reduce the temporary
water storage capacity of the floodplain.
or result in washout of solid waste, so as
to pose a hazard to human life, wildlife,
or land or water resources.
  (b) As used in this section:
  (1) "Based flood" means a flood that
has a 1 percent  or greater-chance of
recurring in any year or a flood of a
magnitude equalled or exceeded once in
100 years on the average over a
significantly long period.
  (2) "Floodplain" means the lowland
and relatively flat areas adjoining inland
and coastal waters, including  flood-
prone areas of offshore islands, which
are inundated by the base flood..
  (3) "Washout" means the carrying
away of solid waste by waters of the
base flood.

§ 257.3-2  Endangered  species.
  (a) Facilities  or practices shall  not
cause or contribute to the taking  of any
endangered or threatened species of
plants, fish, or wildlife.
  (b) The facility or practice shall not
result in the destruction or adverse
modification of the critical habitat of
endangered or threatened species as
identified in 50 CFR Part 17.
  (c) As used in this section: '
  (1) "Endangered or threatened
species" means any species listed as
such pursuant to Section'4 of the
Endangered Species Act.
  (2) "Destruction or adverse
modification" means a direct or indirect
alteration of critical habitat which
appreciably diminishes the likelihood of
the survival and recovery of threatened
or endangered species using that
habitat.
  (3) "Taking" means  harassing,  "
harming, pursuing, hunting, wounding,
killing, trapping, capturing, or collecting
or attempting to engage in such conduct.

§ 257.3-3  Surface Water.
  (a) A facility or practice shall not
cause a discharge of pollutants into
waters of the United States that is in
violation of the requirements of the
National Pollutant Discharge
Elimination System (NPDES) under
Section 402 of the Clean Water Act, as
amended.
  •(b) A facility or practice shall not
cause a discharge of dredged material or
fill  material to waters  of the United
States that is in violation of the
requirements under Section 404 of the
Clean Water Act, as amended.
  (c) A facility or practice shall not
cause non-point source pollution of
waters of the United States that violates
applicable legal requirements
implementing an areawide or Statewide
water quality management plan that has
been approved by the Administrator
under Section 208 of the Clean  Water
Act, as amended.
                                                       297

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53462   Federal Register / Vol.  44, No. 179  /  Thursday. September 13,  1979 / Rules and Regulations
  (d) Definitions of the terms "Discharge
of dredged material". "Point source",
"Pollutant", "Waters of the United
States", and "Wetlands" can be found in
the Clean Water Act. as amended. 33
U.S.C. 1251 et seq., and implementing
regulations, specifically 33 CFR Part 323
(42 FR 37122. July 19. 1977).

{ 257.3-4  Ground Water.
   (a) A facility or practice shall not
contaminate an underground drinking
water source beyond the solid waste
boundary or beyond an alternative
boundary specified in accordance with
paragraph (b) of this section.
   (b) Only a State with a solid waste
management plan approved by the
Administrator pursuant to Section 4007
of the  Act may establish an alternative
boundary to be used in lieu of the solid
waste boundary. A State may  specify
such a boundary only if it finds that
such a change would not result in
contamination  of ground water which
may be needed or used for human
consumption. This finding shall be
based on analysis and consideration of
all of the following factors:
   (1) The hydrogeologica!
characteristics of the facility and
surrounding land;
   (2) The volume and physical and
chemical characteristics of the leachate;
   (3) The quantity, quality, and
directions of flow of ground water
   (4) The proximity and withdrawal
rates of ground-water users;
   (5) The availability cf alternative
drinking water supplies:
   (i) The existing quality of the ground
water including other sources of
contamination  and their cumulative
impacts on the ground  water and
   (7) Public health, safety, and welfare
effects.
   (c) As used in this section:
   (1) "Aquifer" means a geologic
formation, group of formations, or
portion of a formation capable of
yielding usable quantities of ground
water to wells or springs.
   (2) "Contaminate" means introduce a
substance that  would cause:
   (i) The concentration of that
substance in the ground water to exceed
the maximum contaminant level
specified in Appendix I, or
   (ii) An increase in  the concentration of
that substance  in the ground water
where the existing concentration of that
substance exceeds the maximum '
contaminant level specified in Appendix
I.
  (3) "Ground water".means water
below  the land  surface  in the zone of
saturation.
  (4) "Underground drinking water
source" means:
  (i) An aquifer supplying drinking
water for human consumption, or
  (ii) An aquifer in which the ground
water contains less than 10.000 mg/1
total dissolved solids.
  (5) "Solid waste boundary"  means the
outermost perimeter of the solid waste
(projected in the horizontal plane) as it
would exist at completion of the
disposal activity.

S 257.3-5  Application to land used (or the
production of food-chain crop* (Interim
final).
  (a) Cadmium. A facility or practice
concerning application of solid waste to
within one meter (three feet) of the
surface  of land used for the production
of food-chain crops shall not exist or
occur, unless  in compliance with all
requirements of paragraph (a)(l) (i)
through (iii) of this section or all
requirements of paragraph (a)(2) (i)
through (iv) of this section.
  (l)(i) The pH of the solid waste and
soil mixture is 6.5 or greater at the time
of each  solid waste application, except
for solid waste containing cadmium at
concentrations of 2 mg/kg (dry weight)
or less.
  (ii) The  annual application of
cadmium from solid waste does not
exceed 0.5 kilograms per hectare (kg/ha)
on land used for production of tobacco,
leafy vegetables or root crops  grown-for
human consumption. For other food-
chain crops, the annual cadmium
application rate does not exceed:
            Tim* pcnod
                               Annual CO
                             apptcawn raw
                                (kg/rva)
Pr»»»nl lo Jun« X. I9«4 . 	
Jut» 1. 19(4 to O*c 31. 19M..
B«gmrang Jan 1. 1M7	
 10
1.2*
 OJ
  (iii) The cumulative application of
cadmium from solid waste does not
exceed the levels in either paragraph
(a)(l)(iii)(A) of this section or paragraph
(a)(l)(iii)(B) of this section.
  (A)	

             Maximum cumulate* application (kg/ha)
   Sol cation    Background «M pH Background MM pH
 a.cnanot cwac/iy     <»S         >«5
   (maq/ioogi
 IS ..._
                                          t
                                         10
                                         20
  (2)(i) The only food-chain crop
produced is animal feed.
  (ii) The pH of the solid waste and soil
mixture is 6.5 or greater at the time of
solid waste application or at the time
the crop is planted, whichever occurs
later, and this pH level is maintained
whenever food-chain crops are grown.
  (iii) There is a facility operating plan
which demonstrates how the animal
feed will be distributed to preclude
Ingestion by humans. The facility
operating plan describes the measures
to be taken to safeguard against
possible health hazards from cadmium
entering the food chain, which may
result from alternative land uses.
  (iv) Future property owners are
notified by a stipulation in the land
record or property deed which stales
that the property has received solid
waste at high cadmium application rates
and that food-chain crops should not be
grown, due to a possible health hazard.
  (b) Poly-chlorinated Biphenyls (PCBs),
Solid waste containing concentrations of
rCBs equal to or greater than 10 mg/kg
(dry weight) is incorporated into the soil
when applied to land used for producing
animal feed, including pasture crops for
animals raised for milk. Incorporation of
the solid waste into the soil is not
required if it is assured that the PCS
content is less than 0.2 mg/kg (actual
weight) in animal feed or less than 1.5
mg/kg (fat basis) in milk. -
  (c) As used in this section:
  (1) "Animal feed" means any crop
grown for consumption by animals, such
as pasture crops, forage, and grain.
  (2) "Background soil pH" means the
pH of the soil prior to the addition of
substances that alter the hydrogen ion
concentration.
  (3) "Cation exchange capacity" means
the sum of exchangeable cations a soil
can absorb expressed in milli-
equivalents per 100 grams of soil as
determined by sampling the soil to the
depth of cultivation or solid waste
placement, whichever is greater, and
analyzing by the summation method for
distinctly acid soils or the sodium
acetate method for neutral, calcareous
or saline soils ("Methods of Soil
Analysis. Agronomy Monograph No. 9."
C. A. Black, ed., American Society of
Agronomy, Madison. Wisconsin, pp 891-
901, J965).
  (4) "Food-chain crops" means
tobacco, crops grown  for human
                                                           298

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         Federal  Register / Vol. 44, No. 179 / Thursday,  September  13. 1979 / Rules and  Regulations    53463
consumption, and animal feed for
animals whose products are consumed
by humans.
  (5) "Incorporated into the soil" means
the injection of solid waste beneath the
surface of the soil or the mixing of solid
waste with the surface soil.
  (6) "Pasture crops" means crops such
as legumes, grasses, grain stubble and
stover which are consumed by animals
while grazing.
  (7) "pH" means the  logarithm of the
reciprocal of hydrogen ion
concentration.
  (8) "Root crops" means plants whose
edible parts are grown below the
surface of the soil.
  (9) "Soil pH" is the value obtained by
sampling the soil to the depth of
cultivation or solid waste placement,
whichever is greater, and analyzing by
the electrometric methoH. ("Methods of
Soil Analysis, Agronomy Monograph
No. 9," C.A. Black, ed., American
Society of Agronomy, Madison,
Wisconsin, pp. 914-926,1965.)

§ 257.3-6  Disease.
   (a) Disease Vectors. The-facility or
practice shall not exist or occur unless
the on-site population of disease vectors
is minimized through the periodic
application of cover material or other
techniques as appropriate so as to
protect public health.
   (b) Sewage sludge and septic tank
pumpings (Interim Final). A facility or
practice involving disposal of sewage
sludge or septic tank pumpings shall not
exist or occur unless in compliance with
paragraphs (b) (1), (2) or (3) of this
section.
   (1) Sewage sludge that is applied to
the land surface or is incorporated.into
the soil is treated by a Process to
Significantly Reduce Pathogens prior to
application or incorporation. Public
access to the facility is controlled for at
least 12 months, and grazing by animals
whose products are consumed by
humans is prevented for at least one
month. Processes to Significantly
Reduce Pathogens are listed in
Appendix II, Section A. (These
provisions do not apply to sewage
sludge disposed of by  a trenching or
burial operation.)
  (2) Septic tank pumpings that  are
applied to the land surface or
incorporated into the soil are treated by
a Process to Significantly Reduce
Pathogens (as listed in Appendix II,
Section A), prior to application or
incorporation, unless public access to
the facility is controlled for at least 12
months and unless grazing by animals
whose products are consumed by
humans is prevented for at least one
month. (These provisions do not apply
to septic tank pumpings disposed of by a
trenching or burial operation.)
  (3) Sewage sludge or septic tank
pumpings that are applied to the land
surface or are incorporated into the soil
are treated by a Process to Further
Reduce Pathogens, prior to application
or incorporation, if crops for direct
human consumption are grown within 18
months subsequent to application or
incorporation. Such treatment is not
required if there is no contact between
the solid waste and the edible portion of
the crop; however, in this case the solid
waste is treated by a Process to
Significantly Reduce Pathogens, prior to
application; public access to the facility
is controlled for at least 12 months; and
grazing by  animals whose products are
consumed by humans is prevented  for at
least one month. If crops for direct
human consumption are not grown
within 18 months of application or
incorporation, the requirements of
paragraphs (b) (1) and (2) of this section
apply. Processes to Further Reduce
Pathogens are listed in Appendix II,
Section B.
  (c) As used in this section:
  (1) "Crops for direct human
consumption" means crops that are
consumed by humans without
processing to minimize pathogens prior
to distribution to the consumer.
  (2) "Disease vector" means rodents.
flies, and mosquitoes capable of
transmitting disease to humans.
  (3) "Incorporated into the soil" means
the injection of solid waste beneath ,the
surface of the soil or the mixing of solid
waste with the surface soil.
  (4) "Periodic application of cover
material" means the application and
compaction of soil or other suitable
material over disposed solid waste at
the end of each operating day or at such
frequencies and in such a manner as to
reduce the risk of fire  and to impede
vectors' access to the waste.
  (5) "Trenching or burial operation" ,
means the placement of sewage sludge
or septic tank pumpings  in a trench or
other natural or man-made depression
and the covering with soil or other
suitable material at the end of each
operating day such that the wastes  do
not migrate to the surface.

§257.3-7 Air.
  (a) The facility or practice shall not
engage in open burning of residential,
commercial, institutional or industrial
solid waste. This requirement does not
apply to infrequent burning of
agricultural wastes in  the field.
silvicultural wastes for forest
management purposes, land-clearing
debris, diseased trees, debris from
emergency clean-up operations, and
ordnance.                         <
  (b) The facility or practice shall not
violate applicable requirements
developed under a State implementation
plan approved or promulgated by the
Administrator pursuant to Section 110 of
the Clean Air Act.
  (c) As used in this section "open
burning" means the combustion of solid
waste without (1) control of combustion
air to maintain.adequate temperature for
efficient combustion, (2) containment of
the combustion reaction in an enclosed
device to provide sufficient residence
time and mixing for complete
combustion, and (3) control of the
emission of the combustion products.

§ 257.3-8  Safety.
   (a) Explosive gases. The
concentration of explosive gases
generated by the facility or practice_.
shall not exceed:
   (1) Twenty-five percent (25%) of the
lower explosive limit for the gases in  .
facility structures (excluding gas control
or recovery system components); and
   (2) The lower explosive limit for the
gases at the property boundary.
   (b) Fires. A facility or practice shall
not pose a hazard  to the safety of   >
persons or property from fires. This may
be accomplished through compliance
with § 257.3-7 and through  the periodic
application of cover material or other
techniques as appropriate.
   (c) Bird hazards to aircraft. A facility
or practice disposing of putrescible
wastes that may attract birds and which
occurs within 10,000 feet (3,048 meters)
of any airport runway used by turbojet
aircraft or within 5,000 feet (1,524
meters) of any airport runway used by
only piston-type aircraft shall not pose a
bird hazard to aircraft.
  (d) .Access. A facility or practice shall
not allow uncontrolled public access so
as to expose the public to potential
health  and safety hazards at the
disposal site.
  (e) As used in this section:
  (1) "Airport" means public-use airport
open to the public without prior
permission and without restrictions-
within  the physical capacities of
available facilities.
  (2) "Bird hazard" means an increase
in the likelihood of bird/aircraft
collisions that may cause damage to the
aircraft or injury to its occupants.
  (3) "Explosive gas" means methane
(CH,).
  (4) "Facility structures" means any
buildings and sheds or utility or
drainage lines on the facility.
  (5) "Lower explosive limit" means the
lowest" percent by volume of a mixture
of explosive gases which will propagate
                                                         299

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534G4   Federal Register  / Vol.  44. No. 179 /  Thursday. September 13.  1979  / Rules  and Regulations
a flame in air at 25"C and atmospheric
pressure.
   (6) "Periodic application of cover
material" means the application and
compaction of soil or other suitable
material over disposed solid-waste at
the end of each operating day or at such
frequencies and in such a manner as to
reduce the risk of Tire and to impede
disease vectors' access to the waste.
   (7) "Putrescible wastes" means  solid
waste which contains organic matter
capable of being decomposed by
microorganisms and of such a character
and proportion as to be capable of
attracting or providing food for birds.

J 257.4  Effective datt.
   These criteria become effective
October 15. 1979,
Appendix I
   The maximum contaminant levcli
promulgated herein are for use in determining
 whether solid waste disposal activities
 comply with the ground-water criteria
 ({ 257.3-t). Analytical methods Tor these
 contaminants may be Found in 40 CFR Part
 141 which should be consulted in its entirety.
   1. Maximum contaminant levels for
 inorganic chemicals. The following are the
 max< lum levels of inorganic chemicals other
 than iluoride:
                                  kwr)


C*-*^*"
£lSr*y*k..».
i**-?
Hf&r*




005
, „ *
0010
01*
004
000?
to
001
0«5

   The maximum contaminant levels for
 fluoride are:
53 7 and bwow 	
S3 6 lo i« 3
U 4 in 63 •
S3 9 10 70 6 	
707 lo 792 	
793 10 90S 	
12 and twlow 	
12 1 IA 14 A.
14 7 In 178
17 7 10 21 4 	
21 5 10 26 2 	
n 3 10 12 s 	
24
11
to
11
1*
1 4
  1 AnnuaJ av«rao« of tna maximum darfy a» l*mp«raMa
   2. Maximum contaminant levels for
 organic chemicals. The following are the
 maximum contaminant levels for organic
 chemicals:
                                    Lav*
                                   (rrwhorami

 (•) Chkxmaiad nrd'ocatxxtt               *** *
  Enovm   (1.2.].4.l0.lO-H*iacnio'o-6.7-*pO'y.
   1.4.o-2 2
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	Appendix H
 Distribution List

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   Appendix H





Distribution List
         301

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302

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                               DISTRIBUTION LIST


Federal:

U.S.  Department of Interior
U.S.  Department of Housing and Urban Development
Advisory  Council on Historic Preservation
U.S.  Department of Health and Human Services
U.S.  Army' Corps of Engineers
U.S.  Department of Agriculture
U.S.  Department of Transportation
U.S.  Fish & Wildlife Service



State:

Office of the Governor
Department of Game
Department of Ecology
Ecological  Commission
Department of Natural Resources
Historic  Preservation Office
State Parks and Recreation Commission
Interagency Committee for Outdoor Recreation
Department of Fisheries
Department of Social & Health Services
Regional and Local:

Metro Council  Members
Puget Sound Council  of Governments
Tacoma-Pierce  County Health Department
Snohomish County Health District
Skagit County  Health Department
Bremerton-Kitsap County Health Department
Mason County Health  Department
Seattle-King County  Health Department
Thurston County Health Department
Lewis County Health  Department
Snohomish County Council
King County Health Department
Indian Tribes:

Stillaguamish Indian Tribe


                                      303

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Organizations^

Northwest Steel head & Salmon Council
Seattle Audubon  Society
Sierra Club
Industrial Forestry Association
Northwest Motorcycle Association
Washington State Motorcycle Dealers Association
League of Women  Voters of Washington
King County Grange
Friends of the Earth
Washington Environmental Council
Newspapers:

Arlington Times
The Herald
Bel fair Herald
Orting Gazette
Bremerton Sun
Pierce County Herald
Tacoma News Tribune
Seattle Post Intelligencer
Seattle Times
Seattle Daily Journal of Commerce
The Daily Olympian
Individuals:

June Captetto
Richard DuBey
Charles Bigger
Dinnis Dickson
Katherine Hoffman
Joe Hopkins
John C. Larson
Richard Post
Alice Rooney
Perry Sundin
Larry WiIson
Cathy Frojen
Kay Crabtree
Dale Duskin
Jeffrey Hoi beck
Herbert Hower
Mark Lucianna, MD
                                      304

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Bea Randall
Earl  Greathouse
Jeff Tremblay
J. Stuart Torgerson
Georgene Davis
Jerry Hendricks
Clayton Kline
Bernard Peterson
Edna Robbins
Richard &'Rikki Stedman
Robert Williams
Boyd Gallingher
Marc Breuninger
Terry Saflund
Jul Nickers on
Lee Grain
Jeri  Draser
Mary Jane Murphy
Jerry Hagenston
C. Mark Schrader
William Lenz
Clarence Fulfs
Keith Graves
Edgar Hayes
Dr. Marvin West
Dr. James Matthews
Mary Bicknell
Mike Gillett
Betty Lunz
Tony Paulson
Nancy Debaste
R. H. Chambers
Ed Osborn
R. E. Goldhammer
Mr. & Mrs. Esperson
Mr. & Mrs. Peterson
Barry Titus
Dan Swenson
Goodwin F. Olson
Robert Worthley
Gene Monnot
Louis Moody
Frank Olander
Mr. & Mrs. Fryrear
Mr. & Mrs. Lindal
Mr. & Mrs- Schulberg
Don Graham
Bob Burk
Mr. & Mrs. King
Ron Sessa
Glen Kieso
Steve Potter
Lewis Kinney
Hazel ficDougall
Joan Witcher
Wannetta Uilkes
Dick Flyers
Gary Kravagna
Howard Peterson
Doug Ross
Dick Bressler
Ray Potter
Kenneth Shank
Ronald E. Potter
Jean Davis
John Kleyn
Arun Jhaveri
Irvin Potter
Walt Cairns
Warren Hodges
Bill Hunter
Lisa Bieneke
Dan O'Neill
Al Garrett
William Anderson
Craig Seals
Chuck Henry
Duane Weston
John Hauberg
Roger Hicky
Milan Moss
Tom Andrews
Patricia Michels
Jeame Dai ley
Jerry Slind
Art & Marilyn Sill
Joseph E. Simmons
David J. Cox
Virginia King
                                      305

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                           Repository Locations
j_aw Libraries

"Pierce County Law Library
 930 Tacoma Avenue
 123 County-City Building
 Tacoma, KA  9402

°King County Law Library
 621 County Courthouse
 Seattle, WA  98104
 °Kitsap County Law Library
 614 Division Street
 Port Orchard, WA  98366

 "Lewis County Law Library
 North Street Courthouse
 Chehalis, WA  98532

 °Mason County Law Library
 County Courthouse
 She 1 ton,  WA  98584

 °Snohomish County Law Library
 Courthouse
 Everett,  WA  98201

 Newspaper  Libraries

 "Bremerton Sun Library
 545 Fifth Street
 Bremerton,  WA  98310

 "Everett Herald Library
 P.  0.  Box 930
 Everett,  WA  98206

"Seattle Times Library
 Fairview  Avenue  N.  & John  Street
 P.  0.  Box 70
 Seattle,  WA  98111
 Special  Libraries

 "Metro  Library
  821  Second  Avenue
  6th  Floor
  Seattle, WA  98104

 "Municipal Research I  Services
  Center  of Washington  Library
  4719 Brooklyn Avenue  NE
  Seattle, WA  98105

 Public Libraries

 "Enumclaw Public Library
  1309 Myrtle Avenue
  Enumclaw, WA   98022

 "Everett Public Library
 2702 Hoyt Avenue
 Everett, WA  98201

 -King County

 -Black Diamond Public Library
  P. 0. Box  306
  Black Diamond, WA  98010

 -Bellevue Public Library
  11501  Main Street
  Bellevue,   WA  98004

 -Issaquah Public Library
  P. 0.  Box   1048
  Issaquah,   WA  98027

"Kitsap Regional Library
 1301  Sylvan Way
 Bremerton,  WA  98310

"Port  Orchard Public Library
 736 Prospect Street
 Port  Orchard, WA  98366
                                306

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Public Libraries (continued)

"Renton Public Library
 100 Cedar River
 Renton, WA  98055

"Shelton Public Library
 5th & Railroad
 Shelton, WA  98584

"Arlington Public Library
 302 3rd Street
 Arlington, WA  98223

°Snohomish Public Library
 1st & Cedar
 Snohomish, WA  98290

"Tacoma Public Library
 1102 Tacoma avenue S.
 Tacoma, WA  98402

"Timberland North Mason
 Public Library
 Box 161
 Be Ifair, WA  98528

"Kent Public Library
 232 S. Fourth
 Kent, WA  98031

"Magnolia Public Library
 2801-34th Avenue W.
 Seattle, WA  98199
                                307

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
 1. REPORT NO.
     EPA 910/9-83-099
                                                            3. RECIPIENT'S ACCESSION«NO.
 4. TITLE AND SUBTITLE
   Draft Environmental  Impact Statement  -  Municipality
   of Metropolitan  Seattle Sludge Management Plan
              5. REPORT DATE
                 April  1983
              6. PERFORMING ORGANIZATION CODE
 7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS

   Janes & Stokes Associates, Inc.
   2321 P Street
   Sacramento, CA  95816
                                                            10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
   Environmental Protection  Agency, Region  10
   1200  Sixth Avenue
   Seattle, WA  98101
              14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
       The Municipality  of Metropolitan Seattle (Metro) has  identified four
       broad categories  of sludge management  alternatives to  be  pursued over
       the next 15-20 year planning period.   The categories  include composting,
       application to silviculture lands,  application to agriculture lands and
       soil  improvement.   The Draft EIS identifies and evaluates  potential impacts
       of these alternatives  to geology, soils, public health, surface and
       groundwater quality,  land use, vegetation and crops,  terrestrial wildlife
       and aquatic life.   Recommended mitigation measures are described.   Also
       included is a detailed analysis of  a proposed demonstration  project on
       72 acres of forest  land in Western  Washington.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C. COS AT I Field/Group
   Sludge  Treatment
   Environmental Impact Statements
   Land Application(Wastes)
  Seattle, Washington
 8. DISTRIBUTION STATEMENT
                                               19. SECURITY CLASS (ThisReport)'
                                                                          21. NO. OF PAGES
                                              20. SECURITY CLASS (Thispage)
                                                                         22. PRICE
EPA Form 2220-1 (9-73)

-------
                                                          INSTRUCTIONS

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   2.   LEAVE BLANK

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   4.   TITLE  AND SUBTITLE                                                                                 ,  ...           .,
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        number and include subtitle for the specific title.

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        approval,  date of preparation, etc.j.

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        Give name(s) in conventional order (John R. Doe, J. Robert Doe,  etc.).  List author's affiliation if it differs from the performing organi-
        zation.

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        Insert if performing organization wishes to assign this number.

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    10.  PROGRAM ELEMENT NUMBER
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    11.  CONTRACT/G RANT NUMBE R
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    12.  SPONSORING AGENCY NAME AND ADDRESS
        Include ZIP code.

    13.  TYPE OF REPORT AND PERIOD COVERED
        Indicate interim final, etc., and if applicable, dates covered.

    14.  SPONSORING AGENCY CODE
        Leave blank.

    15.  SUPPLEMENTARY NOTES
        Enter information not included elsewhere but useful, such as:  Prepared in cooperation with. Translation of, Presented at conference of.
        To be published in, Supersedes, Supplements, etc.

    16.  ABSTRACT
        Include a brief (200 words or less)  factual summary of the most significant information contained in the report.  If the report contains a
        significant bibliography or literature survey, mention it here.

    17.  KEY WORDS AND DOCUMENT ANALYSIS
        (a) DESCRIPTORS - Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms that identify the major
        concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.

        (b) IDENTIFIERS AND OPEN-ENDED TERMS - Use identifiers for project names, code names, equipment designators,  etc.  Use open-
        ended terms written in descriptor form for those subjects for which no descriptor exists.

        (c) COSATI FIELD GROUP - Field and group assignments are to  be taken from the 1965 COS ATI Subject Category List. Since the ma-
        jority of documents are multidisciplinary in nature, the Primary Field/Group assignment(s) will  be specific discipline, area of human
        endeavor, or type of physical object. The application(s) will be cross-referenced with secondary Field/Group assignments that will follow
        the primary posting(s).

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EPA Form 2220-1 (9-73) (Reverie)

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