EPA 910/9-83-103
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle, WA 98101
August 1983
Water
EPA/10 SEATTLE WA WWTW-83
«>EPA Environmental
Impact
Statement
Final
Municipality of Metropolitan Seattle
Sludge Management Plan
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
4
SEATTLE,
August 19, 1983
0 SEATTLE, WASHINGTON 98101
REPJ.VTO M/S 443
TO: All Interested Government Agencies, Public Groups and Citizens
Enclosed for your review and comment is the Final Evironmental 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, August 26, 1983, which will begin a 30-day review
period. If you have any comments on the Final EIS, we would appreciate
hearing from you before the close of the comment period on September 26,
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 M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Following the close of the comment period, EPA will prepare a Record of
Decision as required by 40 CFR 1505.2. Copies of the Record of Decision
will be available by request from the above address.
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
MUNICIPALITY OF METROPOLITAN SEATTLE
SLUDGE MANAGEMENT PLAN
Prepared by:
U. S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Kathryn Davidson, Project Officer
With Technical Assistance from:
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, California 95816
August 1983
Responsible Official:
?/? . f.} -a.
Ernesta B. Barnes
Regional Administrator
August 11, 1983 '
Date
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TABLE OF CONTENTS
FOREWORD i
EPA Proposed Decision i
General Responses to Most Frequent Comments on iv
Draft EIS
EXECUTIVE SUMMARY 1
Purpose and Need for Action 1
Role of Environmental Impact Statement 2
Description of Alternatives 2
Assessment of Impacts 6
Public Involvement 13
CHAPTER 1 - INTRODUCTION 15
Environmental Impact Statement Requirement 15
Organization of the EIS 15
Metro's Sludge Management Plan 16
EIS Context 17
Public Participation 19
Legal, Policy, and Institutional Considerations 19
CHAPTER 2 - DESCRIPTION OF SLUDGE MANAGEMENT ALTERNATIVES 21
Overview of Sludge Management Concepts 21
Metro's Existing Sludge Management Methods 25
Existing Metro Sludge Characteristics 33
Description of Alternatives Considered by Metro 40
Metro's Recommended Sludge Management Program 52
Metro's 1983 and 1984-1988 Utilization Goals 56
Approach to EIS Evaluation of Alternatives 60
CHAPTER 3 - ENVIRONMENTAL SETTING AND IMPACT OF 65
ALTERNATIVES
Introduction 65
Impacts of Sludge Processing 65
Impacts of Metro's Recommended Alternatives 68
Economic Impacts of Metro's Preferred Long-Range 91
Alternatives
Impact Analysis of the Pilchuck Tree Farm 91
Demonstration Project
CHAPTER 4 - COORDINATION 167
Introduction 167
Public Participation 167
Schedule for Final EIS Review 169
CHAPTER 5 - LIST OF EIS PREPARERS 171
CHAPTER 6 - BIBLIOGRAPHY 175
Documents 175
Personal Communications 186
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TABLE OF CONTENTS (CONTINUED)
Page
CHAPTER 7 - COMMENTS RECEIVED ON DRAFT EIS AND RESPONSES 189
TO COMMENTS
Introduction 189
Summary of Public Hearings 189
Federal Agencies 191
State Agencies 199
Local Agencies 211
Citizens 219
APPENDIX A - PUBLIC HEALTH A-l
APPENDIX B - PROPERTIES OF FOREST SOILS B-l
APPENDIX C - SILVICULTURAL HISTORY, PILCHUCK SLUDGE C-l
APPLICATION SITES
APPENDIX D - ENDANGERED AND THREATENED SPECIES, PILCHUCK D-l
TREE FARM DEMONSTRATION SITE
APPENDIX E - CULTURAL RESOURCES, PILCHUCK TREE FARM E-l
DEMONSTRATION SITE
APPENDIX F - WATER QUALITY AND GROUNDWATER DATA F-l
APPENDIX G - EPA CRITERIA FOR CLASSIFICATION OF SOLID G-l
WASTE DISPOSAL FACILITIES AND PRACTICES (40 CFR
PART 257)
APPENDIX H - FEDERAL REQUIREMENTS RELEVANT TO SLUDGE H-l
MANAGEMENT AND DISPOSAL
APPENDIX I - ADVISORY COMMITTEE STATEMENTS 1-1
APPENDIX J - ASSESSMENT OF LAND VALUE J-l
APPENDIX K - DISTRIBUTION LIST K-l
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LIST OF TABLES
Table
S-l Impacts of Sludge Processing and Transportation 7
S-2 Impacts of Land Application of Sludge 8
S-3 Impacts of the Pilchuck Demonstration Project 10
S-4 List of Possible Permits and Approvals Required 12
by Metro
2-1 Metro's Past Sludge Disposal and Demonstration 32
Programs
2-2 Metro Sludge Quantities 1978-1982 34
2-3 Existing Sludge Physical, Chemical, and Micro- 39
bial Quality
2-4 Description of Long-Term Sludge Management 42
Alternatives
2-5 Costs of Feasible Alternatives 47
2-6 Metro's Proposed Sludge Management Goals 53
2-7 Sludge Distribution 1984-1988 58
2-8 Estimated Truck Loads, Trips Per Day and Hauling 62
Days, Pilchuck Tree Farm Demonstration Project
3- 1 Energy Production for the Various Project 66
Alternatives
3-2 Projected Truck Traffic From the Renton and 67
West Point Treatment Plants, 1980-2000
3- 3 Projected Annual Fuel Consumption for Sludge 70
Trucking for Each Feasible Alternative (gal/yr)
3- 4 Air Emissions From Trucking for Each Feasible 71
Alternative
3- 5 Nutrient and Metal Contents of Municipal Sludge 77
Compost
3- 6 Species Suitability Classes 83
3- 7 Projected Monthly Base Rates for the Long-Range 93
Sludge Management Alternative (Year 1990)
3- 8 Comparison of Present Worth Costs for Sludge 94
Management Away from Treatment Plants; Single
Alternative Approach Versus Recommended Program
Approach
3- 9 Summary of Proposed Costs for Program Implemen- 95
tation
3-10 Construction-Related Impacts of Storage and 99
Access Road Construction, Pilchuck Tree Farm
3-11 Comparison of Chemical Characteristics of the 105
Pilchuck Tree Farm Soil and West Point
Digested, Dewatered Sludge
3-12 Projected Loadings of Heavy Metals per Hectare, 107
Pilchuck Demonstration Project
3-13 Hydrologic Data for Rock Creek, Kunze Creek, 112
and North Fork of the Stillaguamish River
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LIST OF TABLES (CONTINUED)
Table
3-14 Water Quality Data for Rock Creek and Kunze
Creek
3-15 Pilchuck Tree Farm Soil and Water Quality
Monitoring Program
3-16 Metro Contaminant Monitoring Project -
Parameters
3-17 Depth to Water, Hydraulic Conductivity and
Water Level Elevations of Test Wells, Pil-
chuck Tree Farm Demonstration Project
3-18 Metal Concentrations in Plant Species Found on 127
Sludge-Treated and Control Areas at Pack
Experimental Forest
3-19 Population Changes from 1970 to 1980 in Census 140
Tracts in the Vicinity of the Pilchuck Tree
Farm
3-20 Quantities Which Must be Consumed at One Time 155
to Result in Salmonellosis and the Time Re-
quired for an Average Adult to Consume that
Quantity
3-21 Quantities Which Must be Consumed at One Time 156
to Result in Enterovirus Infection and the
Time Required for an Average Adult to Consume
that Quantity
3-22 Quantities Which Must be Consumed at One Time 158
to Result in Ascaris/Giardia Infection and the
Time Required for an Average Adult to Consume
that Quantity
3-23 Daily Human Consumption Necessary to Cause 159
Health Problems from Cadmium or Lead
3-24 Quantities Which Can be Consumed on a Con- 162
tinuous 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 the 22
Method of Disposal
2-2 Metro's Wastewater Treatment Plants and Sludge 26
Transfer Facilities
2-3 Flow Diagram of Metro's Sludge Treatment and 28
Disposal Processes
2-4 Existing Sites for Reuse of Metro Sludge 29
2-5 Pounds of Sludge Pumped to West Point 35
2-6 Monthly Variation in Metro's Sludge Production 36
2-7 Summary of Future Sludge Quantity 37
2-8 Location of the Pilchuck Tree Farm, Arlington, 59
Washington
2-9 Proposed Sludge Application Sites and Facili- 61
ties, Pilchuck Tree Farm, Arlington, Washington
3- 1 Forest Lands Potentially Suitable for Sludge 77
Application Located Within 95 Miles of Seattle
3- 2 Proposed Sludge Application Sites and Facili- 97
ties, Pilchuck Tree Farm, Arlington, Washington
3- 3 Geologic Features of the Pilchuck Site 101
3- 4 Surface Water Resources of the Pilchuck Demon- 109
stration Project, Arlington, Washington
3- 5 Surface and Groundwater Monitoring Stations, 118
Pilchuck Tree Monitoring Project
3- 6 Well Location, Pilchuck Tree Farm, Arlington, 120
Washington
3- 7 Zoning in the Project Vicinity 135
3- 8 Projected 1990 Land Uses 137
3- 9 Census Tracts in the Vicinity of the Pilchuck 139
Tree Farm
3-10 New Residential Development in the Project 142
Vicinity
3-11 Haul Route (Outside Pilchuck Tree Farm) 144
3-12 Local Haul Route 145
3-13 Possible Pathways of Microbial Transport Out of 153
Sludge in a Silvicultural Application
3-14 Pathways of Metals Transport From Sludge in a 160
Silvicultural Application
3-15 Pathways for Organic Toxicant Transport From 156
Sludge to Environmental Compartments in
Silvicultural Application
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FOREWORD
The Final Environmental Impact Statement (EIS) has been
prepared by the U. S. Environmental Protection Agency (EPA) to
describe the environmental impacts associated with EPA's pro-
posed approval of the Municipality of Metropolitan Seattle's
(Metro) Final Sludge Management Plan. This Final EIS has been
prepared pursuant to the National Environmental Policy Act
(NEPA) of 1969 and implementing federal regulations, and will be
used to satisfy Metro's environmental review responsibilities
under the Washington State Environmental Policy Act (SEPA).
EPA's objective in taking action on Metro's Sludge Manage-
ment Plan is to assist Metro in fulfilling the requirements for
a complete facilities management program for the Renton Waste-
water Treatment Facilities, and thereby working toward achieving
the goals of the federal Clean Water Act.
EPA previously circulated a Draft EIS on Metro's Draft
Sludge Management Plan. Comments on the Draft EIS were received
during a 45-day review extending from April 15, 1983 to May 31,
1983. Two public information meetings and two public hearings
were held in May 1983 to receive comments from citizens, organi-
zations, and agency staffs. Based on public and agency comment,
and additional environmental analysis, EPA has identified a
proposed decision relative to Metro's Sludge Management Plan.
EPA Proposed Decision
Federal funding for the design and construction of waste-
water or sludge facilities typically follows the preparation of
a federally funded facilities plan, in this case Metro's Sludge
Management Plan.
Metro has indicated that federal funding will not be sought
for design or construction of the sludge processing facilities
or for any proposed facilities upgrading at the Renton Treatment
Plant. However, Metro will request federal funding for purchase
of land and some equipment for land application of sludge.
Because federal funds were utilized for preparation of
Metro's Sludge Management Plan and may be utilized for future
land and equipment purchase, EPA must take action to approve,
disapprove or conditionally approve Metro's Sludge Management
Plan. Since the Pilchuck Demonstration Project does not require
federal approval, Metro could proceed with the project even if
EPA does not approve Metro's Sludge Management Plan. Addition-
ally, EPA will carry out appropriate environmental review for
any future land application sites to be federally funded.
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Five principal statutory authorities presently represent
the basis for EPA regulations associated with sludge management:
1) the Resource Conservation and Recovery Act (RCRA), 2) the
Clean Water Act, 3) the Marine Protection, Research, and Sanctu-
aries Act, 4) the Clean air Act, and 5) the Toxic Substance
Control Act (TSCA). Two clear mandates relating to sludge have
been established through those statutes: to promote the benefi-
cial utilization of sludge and to protect the public health and
the environment.
To date, EPA has taken two major actions in the area of
beneficial reuse of sludge. First, EPA has promulgated interim
final regulations for the application of solid waste (including
sewage sludge) on land where foodchain crops are grown (see
Appendix G). EPA has also initiated hearings on regulations
governing the distribution and marketing of fertilizers and soil
conditioners containing municipal sewage sludge. These two
components (sludge application for growing foodchain crops and
distribution and marketing of soil conditioners) are parts of
what will eventually become an EPA comprehensive sludge manage-
ment program.
EPA recognizes that, with proper pretreatment, use of
processes to significantly reduce pathogens in sludge, and
proper site management (i.e., selection of proper sites, manage-
ment of application rates and use of monitoring programs), land
application of sludge can represent a beneficial resource use.
EPA is proposing to approve Metro's plan to utilize
sludge for silvicultural application, soil improvement
and the production of a composted sludge product.
Metro's Sludge Management Plan
Metro's management plan identifies goals for the
recommended distribution of sludge as follows: silvicultural
application - 65 percent; soil improvement - 25 percent; and
composting - 10 percent. Furthermore, Metro recommends the use
of sludge storage basins with capacities to handle a full year
of sludge production, as a contingency for proposed land appli-
cation.
The use of sludge on forestlands has been studied for
approximately 9 years at the University of Washington Pack
Forest near Eatonville. Those studies have indicated that
sludge can be reused beneficially and have evaluated the impacts
of sludge on various components of the forest ecosystem.
Although not all possible impact considerations have been
evaluated in these studies, the results of those studies com-
pleted have shown the adverse environmental and public health
impacts to be minimal given proper siting, site management, and
monitoring.
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The application of sludge to improve soil fertility and
organic content has been carried out throughout the United
States for many years and is a recognized means of improving
soil that has been drastically disturbed by man's activities.
The Chicago Metropolitan Sanitary District for example, has
applied sludge for 10 years to approximately 40,000 acres of
strip-mined land and since 1978, Metro has hauled sludge to the
Washington Irrigation and Development Company (WIDCO) coal strip
mines near Centralia, Washington for purposes of soil improve-
ment. Metro has also applied sludge for soil improvement
projects throughout Seattle and at landfill sites in King
County. The Washington Department of Ecology (DOE) (1982) has
developed best management practices (BMPs) for the application
of sludge on drastically disturbed land. The BMPs include the
proper means of site selection, storage, sludge handling and
application, and necessary site monitoring.
Composting and distribution of sludge constitutes approxi-
mately 12 percent of the means of sludge disposal throughout the
United States (Peter in Bledsoe 1981). In the past, much of the
sludge composted in the United States has been distributed in an
unrestricted manner. EPA has recognized that such uncontrolled
use cannot continue and has drafted regulations relative to two
types of composted sludge products: fertilizers and soil
conditioners. The DOE has also established BMPs for site
selection and application criteria for the use of composted
sludge in Washington State.
In proposing to approve Metro's option to use sludge for
composting purposes, EPA recommends that the mitigation measures
recommended in the EIS are enacted and that DOE BMPs are
utilized. Future EPA regulations may restrict the distribution
of composted sludge if heavy metal concentrations are too high
for garden and food chain use. The ultimate use of composted
sludge would have to conform with those future regulations.
Metro's decision-making process and schedule will include
review and approval of the Sludge Management Plan and Pilchuck
Demonstration Project by Metro's Water Quality Committee and the
Metro Council. Metro has indicated that the Pilchuck Demon-
stration Project will proceed on a schedule independent of the
schedule for the Sludge Management Plan. The Pilchuck schedule
calls for Metro Water Quality Committee and Council review and
approval during first 2 weeks of September 1983 while the Sludge
Management Plan is scheduled for later in 1983.
Pilchuck Tree Farm Demonstration Project
The Draft and Final EISs included an impact analysis of
Metro's proposed sludge application demonstration project at the
Pilchuck Tree Farm, Arlington, Washington.
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As with the other components of Metro's Sludge Management
Plan, no federal funding is anticipated for either design or
construction of the Pilchuck project. Therefore, Metro could
proceed with the Pilchuck project prior to plan approval by EPA.
Metro will utilize this EIS to satisfy SEPA requirements. At
this time it is anticipated that the Metro Water Quality Commit-
tee will make a recommendation on September 8, 1983 and that the
Metro Council will make a decision on September 15, 1983. The
regulatory approval of the project lies with the Snohomish
Health District (Permit for Land Application of Sludge) and the
DOE (approval of Metro's Sludge Management Plan and Report of
Findings for the Land Application Permit issued by the Snohomish
Health District).
EPA has established that, given Metro's proposed plan for
sludge application; the known quality of the sludge; the results
of site-specific hydrological, geological, soils and water
quality studies; sludge can be applied at the proposed site with
a minimum of impact and public risk. The need for a detailed
operation and sludge application plan is essential and should be
a requirement prior to initiation of the project. In addition,
it is recommended that the mitigation measures as described for
the Pilchuck project in this EIS be required as a part of
project approval.
Lastly, EPA recommends that, as requested by the 201
Citizens' Advisory Committee on Sludge and the Sludge Project
Citizens' Advisory Committee (Arlington), Metro continue to
pursue means of improving the quality of the sludge through
pretreatment and nonpoint source pollutant control. The con-
tinued improvement of sludge quality will allow Metro greater
flexibility in uses of sludge in the future.
Individuals or groups that wish to comment in writing on
the Final EIS may forward written comments to:
U. S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Attn: Kathryn Davidson
Comments should be sent by the close of the 30-day comment
period on September 26, 1983. All comments received will be
considered by EPA. EPA's final decision will be documented in
the Record of Decision to be completed after the close of the
comment period.
General Responses to Most Frequent
Comments on Draft El"S
Many comments received on the Draft EIS raised similar
issues and concerns. Although answers to the questions are
IV
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found throughout either the text to the EIS, Metro's Sludge
Management Plan or the Draft Plan for the Pilchuck Tree Farm
Demonstration Sludge Application Project, it is beneficial to
present them in one central location.
In addition to the response to comments provided herein,
answers to specific letters of comment are presented in Chap-
ter 7 of this Final EIS and in a "Responsiveness Summary"
prepared by Metro and mailed to attendees of the public meetings
and hearings and to those submitting letters of comment on
either the Draft Sludge Management Plan or the Draft EIS.
While some of the comments received were relevant to
Metro's long-range sludge management alternatives and options
for land application of sludge, a majority of the concerns were
related to application of sludge on the Pilchuck Tree Farm. The
following comments are grouped into those two areas of consid-
eration.
Metro's Sludge Management Plan
1. Wouldn't implementation of a strict pretreatment program
for industrial wastes help eliminate contaminants found
in sludge?
Many commentors felt that Metro should aggressively carry
out a more stringent pretreatment program in order to minimize
the impact of persistent toxic substances (heavy metals and
organics) and to maximize the options for land application of
sludge (e.g., allow for greater loading of sludge per acre if
applied for food chain agriculture).
Depending on the specific metal, industries contribute
20-80 percent of the metals in sludge. Metro anticipates that
three major factors could affect the characteristics of sludge
in the future: 1) changes in industrial pretreatment standards
could reduce quantities of heavy metals entering the wastewater
stream; 2) input of trace metals from the domestic water supply
is expected to decrease slightly as a result of the City of
Seattle Water Department corrosion control program (i.e.,
reductions in levels of copper and zinc); and 3) the
consideration for separating most industrial flows from West
Point flows and treating them separately at a Duwamish
wastewater treatment plant.
Analysis of organic compounds has focused on those iden-
tified by EPA to be of major concern in municipal sludges. The
sampling conducted by Metro showed that: 1) pesticides and
herbicides were generally not detectable in Metro's sludge and,
2) PCBs were present in very low concentration.
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EPA has recommended on page iv of the FOREWORD of this EIS,
that Metro continue to pursue means of improving sludge quality
through source control.
2. Why doesn't Metro pursue the incineration of sludge or
converting sludge to useful energy through methane
generation or co-incineration with municipal solid
waste?
As required by EPA regulations Metro has conducted analysis
of both monetary and nonmonetary factors affecting alternative
methods of sludge disposal. The cost-effectiveness portion of
the analysis was included as Appendix C to Metro's Draft Sludge
Management Plan. Metro rejected the alternative of sludge
thermal conditioning with incineration (Alternative 4A) because
of the large amounts of energy required for operation and
because of the problems associated with reliability, odor, and
other operational problems. The City of Seattle and King County
are presently evaluating the feasibility of constructing a solid
waste-to-energy recovery facility which could also conceivably
receive sewage sludge mixed with the municipal solid waste
stream. The co-generation with municipal solid waste alterna-
tive (Alternative 4B) was deferred by Metro until a later time
in the planning period. Metro has indicated that coordination
with the City of Seattle and King County will continue to be
carried out.
The present worth costs of three incineration alternatives
evaluated by Metro range from $81.6 to $108.8 million (Renton
only), compared to a cost range of $77.4 to $95.7 million for
Renton facilities for silvicultural application (Alternatives 7A
to 7D).
Methane gas is now generated and recovered during the
sludge anaerobic digestion process at Metro's West Point Treat-
ment Plant. Methane gas is used to operate the plant and to
generate electricity for purchase by Seattle City Light.
Pilchuck Tree Farm Sludge Application Project
The greatest number of questions and comments were asso-
ciated with proposed sludge application at the Pilchuck Tree
Farm.
3. What was Metro's methodology and rationale for selecting
the proposed sludge application areas at the Pilchuck
Tree Farm?
The Pilchuck Tree Farm was interested in the beneficial
results of sludge application on forestlands as determined by
the University of Washington's research at Pack Forest. The
tree farm management elected to cooperate with Metro on the
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basis of Metro's previous experience with land application of
sludge.
During the planning process for the project, Metro and tree
farm management identified 24 sites on the 2,335-acre Armstrong
Tract having characteristics suitable for sludge application.
Metro then conducted on-site studies and applied site selection
criteria to each of the sites. The proposed 70-acre site was
ultimately selected because it was best suited for sludge
application of all sites evaluated. Recommendations made by the
Citizen's Advisory Committee were also considered in the choice
of sites.
4. How will the application sites be controlled to prevent
access by children and domestic animals?
The proposed application sites are bounded on three sides
by steep, heavily vegetated slopes along the North Fork Stilla-
guamish and Rock and Kunze Creeks. According to Metro, access
along the northern boundary of the site will be controlled by
fencing and barriers. Metro will also initiate a program of
directly informing people in the area when the proposed applica-
tion is scheduled. Additionally, Metro has indicated that a
6-foot-high chainlink fence will be constructed along the entire
northern boundary of the site which would remain for a least
1 year following application. Such a measure would prevent
children and large domestic animals from entering the site.
Such measures would effectively reduce the likelihood of expo-
sure to land applied s-ludge and to the quantities of sludge
necessary to cause health problems.
5. What will be the effects of sludge application on
wildlife and berries or mushrooms that might be
ingested by humans?
A number of commentors were concerned about the effects of
sludge on wildlife and on humans, if the wildlife, berries or
mushrooms were consumed that were grown on sludge-amended land.
Studies conducted by the University of Washington have
indicated that few wildlife species are affected by sludge
application. In the course of normal day-to-day activities,
wildlife species will come in contact and will ingest sludge
along with the normal food supply. Cadmium is a heavy metal
most often analyzed relative to accumulation in internal organs
of wildlife species, particularly in the kidneys and liver.
Some increase in cadmium levels in those organs can be expected,
however, based on research at Pack Forest, such concentrations
are expected to be well below those known to be acutely toxic to
animals and humans. In Appendix B of the Draft Sludge Manage-
ment Plan, Metro has concluded that there will be no increased
health risk from the normal consumption of deer liver and
kidney, but that such consumption should not be done on a daily
basis.
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Little is known of the potential chronic toxicity impacts
on wildlife or bioaccumulation in the vast majority of wildlife
species. The University of Washington has initiated wildlife
studies in Pack Forest as a part of the Pilchuck demonstration
project. Monitoring of wildlife conditions will be undertaken
to answer some of the questions associated with affects on wild-
life.
Additional studies have been initiated on mushrooms and
berries since neither has been studied in the past, although
research has been done on agricultural crops grown on sludge-
amended soils.
6. What is the potential for health or unknown long-term
risks to people? Why aren't there any standards for
organic or chemical contamination in groundwater? The
projected nitrate increases to the groundwater resulting
from sludge application are too high.
An assessment of risks associated with the proposed sludge
application program has been carried out as a part of the EIS
and by Metro as a part of the Draft Sludge Management Plan
(Appendix B) .
The public health risk is associated with two factors:
1) the likelihood of exposure to microbial, heavy metal or
organic contaminants, and 2) if people are exposed to contami-
nants, what is the minimal dose which will cause infection?
In EPA's estimation, Metro has planned the application
project to minimize the exposure of the public during sludge
application and for 1 year thereafter. The use of buffer zones
and fencing and the groundwater characteristics of the site
(trending away from private wells located north of the site) all
limit the likelihood of public exposure to pathogenic organisms,
heavy metals, etc. Sludge haulers and handlers at the site will
have the greatest exposure to sludge. Handling procedures are
already in use to minimize risk to human health.
Calculations have been made of the quantities of soil, air,
water or other mechanisms of transmission, needed to cause
infection or to reach maximum permissible concentrations as
defined by EPA or other agencies (i.e., maximum permissible
concentration for cadmium, PCBs or nitrates). Results of those
calculations have shown the risk to be low given a number of
precautions (e.g., livers, kidneys, and fatty tissues from game
harvested on the site not be consumed on a daily basis).
Regarding the question of standards for chemical contamina-
tion of groundwater, EPA has established water quality standards
for a drinking water supply through Section 303 of the Clean
Water Act. Additionally EPA's criteria for classification of
solid waste disposal facilities and practices (40 CFR Part 257)
includes criteria (section 257.3-4) for groundwater
Vlll
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contamination by inorganic and organic chemicals (see Appendix G
of this EIS). Furthermore, EPA as a part of Section 304(a) of
the Clean Water Act, published water quality criteria for
priority toxic pollutants which reflect the latest scientific
knowledge on the identifiable effects of pollutants on public
health and welfare, aquatic life, and recreation.
The nitrate concentrations projected beneath the applica-
tion site would be less than the EPA drinking water standard of
10 mg/1 nitrate. Nitrate concentrations are expected to decline
each year following application as nitrate leaching diminishes.
The projected increase to a maximum of 8.3 mg/1 nitrate is
judged to be acceptable given the fact that the levels will be
less than the maximum allowable value of the water quality
standard.
7. Truck traffic will constitute a nuisance and will damage
roads. Why does truck traffic need to be continued into
the night?
A number of commentors at the public meetings and public
hearings expressed concern over the proposed sludge hauling
schedule and routes.
Metro has indicated that from 4-9 trucks per day will be
traveling the haul route, with hauling to be conducted round the
clock except for a 2-hour period in the morning and 2.5 hours in
the afternoon to avoid congestion during school busing.
The projected round-the-clock hauling schedule is based on
Metro's sludge production and the need to fill the storage basin
at Pilchuck during a short time period prior to the acutal
application. Metro will be working out an agreement with
Snohomish County regarding road maintenance. At this time no
formal agreement has been made. A complete discussion of
trucking haul and the associated impacts is provided in the
Transportation section of this EIS.
IX
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X
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EXECUTIVE SUMMARY
( ) Draft Environmental Impact Statement
(X) Final Environmental Impact Statement
Type of Action: Administrative
Purpose and Need for Action
On October 21, 1980, the Muncipality of Metropolitan
Seattle (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
an effort separate from 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 1980 Environmental Impact Statement (EIS) for the Renton
facilities plan discussed proposed sludge processing facilities
at Renton and the impacts of construction and operation. The
EIS also briefly summarized ongoing Metro planning for sludge
disposal, but did 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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Because federal funds were utilized for preparation of
Metro's Sludge Management Plan and may be utilized for future
land and equipment purchase, EPA must take action to approve,
disapprove or conditionally approve Metro's Sludge Management
Plan.
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 specific
to one of the proposed projects of the Sludge Management Plan -
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.
Since 1973, Metro has undertaken a program of land application
of sludge on demonstration and research sites throughout western
Washington, and a composting program with GroCo, Inc. The
research projects have included 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 50 dry tons per day in 1990, and to 58 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.
Sludge Management Alternatives
Metro 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 6 from further consideration
because of high costs or unacceptable nonmonetary factors.
Metro also "deferred" 5 other alternatives as not presently
feasible for near-term implementation, but which might at some
later date be more closely considered.
The remaining 7 alternatives were recommended by Metro for
additional evaluation. These alternatives were:
o 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 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 7 of the 18 original alternatives were identified
as "recommended", Metro's sludge management plan did not
identify any single specific alternative; rather, Metro
identified goals for the implementation of a combination of
sludge use methods - composting, silviculture, and land
reclamation.
In the Draft Sludge Management Plan, Metro had identified
Agricultural Application (Alternative 1) as a preferred method
of land application of sludge. That alternative was
subsequently deferred because of the lack of suitable land in
western Washington and because other sludge management options
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are available which utilize land closer to the Metro treatment
plants.
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
(composting, silvicultural application, soil improvement) and
the impacts of the 7 project alternatives previously described.
The no-project alternative is also evaluated, as required by EPA
regulations.
Metro's Recommended Plan
Metro identified a number of primary and secondary
management goals, and goals specific to the use of sludge for
silvicultural application, soil improvement, and composting. In
addition, the elements of the recommended program were outlined
as follows:
o In-plant and transport features - Metro has recommended
anaerobic sludge digestion with medium dewatering (18
percent solids) and transport of sludge to land
application sites by 30-cubic-yard or 45-cubic-yard
capacity trucks.
o Silvicultural application - Metro has recommended sludge
application on either forestlands located 30-95 miles
from Metro's treatment plants or land purchased within
45 miles of Metro's plants for the establishment of a
poplar plantation. Metro projects that 65 percent of
sludge production during the planning period would be
used for silvicultural application. The Washington
Department of Ecology's (DOE) Best Management Practices
(BMPs) would be used to select sites. Projects that
Metro will be pursuing under silvicultural application
will include:
- Pilchuck Tree Farm Demonstration Project
- Pack Forest Demonstration Project
- King County Site Demonstration Project
o Soil improvement - Metro has recommended that 25 percent
of the 20-year sludge production be used for soil
improvement purposes. Washington DOE's BMPs would be
used to determine suitability of soil improvement
projects. Projects that Metro has identified as a part
of the soil improvement program include:
- Cedar Hills Landfill
- Discovery Park
- Duvall Landfill
- Edmonds Community College
- WIDCO
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o Composting - Metro will pursue the goal of utilizing 10
percent of the sludge produced for composting.
Additional studies will be done to determine ownership
(Metro vs. private) and operation of compost facilities.
Composting projects will include:
- GroCo Composting
- Metro-owned or private contract for other composting
services
1984-1988 Sludge Utilization Goal. Metro has established
near-term sludge use goals for the years 1984-1988. These goals
include:
1984 1985 1986 1987 1988
PERCENT USED
Silviculture 42 60 63 64 65
Soil Improvement 52 34 27 26 25
Composting 6 6 10 10 10
PROJECTED SLUDGE 79,885 81,375 82,860 84,390 99,430
PRODUCTION (WET TONS
PER YEAR)
1983 Utilization Goal. Additionally, Metro has defined a
goal for distributing sludge during the current year. The
quantities of sludge to be delivered to the sites are as
follows:
ESTIMATED AMOUNT (WET TONS) PERCENT
AMOUNT AND PERCENT USED
Silviculture 4.7
Pack Forest 3,676
Soil Improvement 79.4
WIDCO 50,583
Duvall Landfill 1,500
Discovery Park 1,657
Edmonds Community College 4,500
Cedar Hills Landfill 4,196
Compost
GroCo 8,809
TOTAL 74,921
1983 PROJECTED SLUDGE PRODUCTION 78,640
ADDITIONAL CAPACITY REQUIRED 3,719
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Assessment of Impacts
Sludge Management Categories
The environmental impacts and potential mitigation measures
of the three broad sludge management categories (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 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 this 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 jurisdictions.
Pilchuck Project
An analysis of the impacts associated with the Pilchuck
demonstration project is presented in this EIS following the
assessment of impacts of the Sludge Management Plan.
Permit and Approval Requirements
As part of the planning and regulatory process, Metro would
need to obtain permits or approvals from a variety of state and
local entities. A list of permit and approval 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
requirement for an approved sludge management plan would not be
met.
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Table S-l. Impacts 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 19,710 to 359,890
gallons.
Minor construction impacts only
with Alternative 2A (Taulman-
Weiss tank composting)
Increases in sludge hauling
traffic from the Renton treat-
ment plant from no trucks/day
in 1983 to 7/day by the year
2000; increases from 9 trucks/
day in 1983 at West Point to
IQ/day by 1987, then a decrease
to 7/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
Land use
Worker exposure to com-
posted sludge
Water quality
Public health
CO
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 .
Design 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.
Design the site with an impervious surfac<
area and runoff collection system connec-
ted to a sewer.
Future regulations will dictate ultimate
use of composted material; labeling for
consumer protection could be provided on
compost bag.
Provide adequate warning to consumers to
use composted sludge only on nonfood-
chain crops.
Conduct studies to examine the hazard
posed by pathogenic fungi and bacteria.
Geology and soils
Silviculture
Surface and groundwater
Terrestrial wildlife and
aquatic life
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.
Increase in growth response of Douglas-
fir, SiLka spruce,', poplar and coltonwooU;
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.
Use of DOE BMPs to identify proper sites
for sludge application.
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.
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Table s-2. Cont'd.
Area of Impact
Description of Impact
Mitigation Measures
Soils
Land use
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
1982a).
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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 ot Armstrong
Road.
Carefully select sludge vehicle travel
routes.
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 ISO
feet from cliff edge.
Locate high visibility markers at edge of
buffer zone.
Check structural integrity of Kunze
Creek bridge.
Cease sludge application if ground
should freeze or during high rainfall.
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.
Initiate study of importance of wildlife
as disease vectors.
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.
Exposure of young children and domestic
animals to sludge.
Utilize results of studies to determine
if site should be closed to picking
berries and mushrooms for longer than 1
year.
Installation of a 6-foot-hiqh chainlink
fence along the northern boundary of the
site.
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Table S-4. List of Possible
by
STATE AND LOCAL
Department of Ecology
Office of Archeology and
Historic Preservation
Departments of Fisheries and
Game
Snohomish Health District,
Environmental Health Division
Permits and Approvals Required
Metro
PERMIT OR APPROVAL
State Environmental Policy Act
201 Facilities Plan Approval
Section 201-PL92-500/Clean Water
Act
Shoreline Management Permit
State Waste Discharge Permit
NPDES Permit
Report of Findings for the Land
Application Permit issued by the
Snohomish Health District
(Chapter 70.95.180 RCW).
Project Approval
Hydraulic Permit (already issued)
Land Application of Sludge Permit
12
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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
Sludge Management Program. Key EIS public participation
activities have included publication and distribution of an EIS
information brochure, conducting scoping meetings, public
information meetings, and an EIS presentation to the Citizens'
Advisory Committees.
The Draft EIS was forwarded to numerous federal, state, and
local agencies, special interest groups, private citizens, and
public libraries to act as both an informational document and as
an avenue to comment on the proposed wastewater project. (The
EIS mailing list is presented in Appendix K.)
Joint Metro/EPA public hearings were conducted in May 1983
in Seattle and Arlington, Washington. During those public
hearings, formal oral and written testimony was received. A
summary of the hearings and responses to the letters of comment
are presented in Chapter 7 of this EIS.
Individuals or groups that wish to comment on the Final 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 September 26, 1983, the close of
the 30-day comment period on the Final EIS. All comments will
be considered by EPA in reaching its final decision following
the close of the comment period.
13
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Chapter 1
Introduction
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Chapter 1
INTRODUCTION
Environmental Impact Statement Requirement
The Municipality of Metropolitan Seattle (Metro) has
prepared Draft and Final Sludge Management Plans for managing
sewage sludge produced at the Metro wastewater treatment facili-
ties. This Final Environmental Impact Statement (EIS) has been
prepared by the Environmental Protection Agency (EPA), Region
10, to assess the Sludge Management Plan's environmental conse-
quences.
The relevant EPA decisions are to approve the Sludge
Management Plan, the preparation of which is partially federally
funded. This EIS satisfies EPA's environmental review respon-
sibilities 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 Final 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 briefly summarizes relevant legal,
policy and institutional considerations.
Chapter 2 of the EIS provides an overview of sludge manage-
ment concepts, a description of Metro's existing sludge manage-
ment 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; Chapter
5 lists the EIS preparers; Chapter 6 contains the Bibliography;
and Chapter 7 incorporates written comments received on the
Draft EIS and responses to those comments.
15
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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), endan-
gered and threatened species (Appendix D), cultural resources
(Appendix E), water quality and groundwater data (Appendix F),
and EPA criteria on solid waste disposal (Appendix G), Appendix
H - legal and policy considerations, Appendix I - Advisory
Committee statements, Appendix J - assessment of land values,
and Appendix K, the EIS distribution list.
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. Con-
struction of those facilities is scheduled to begin in mid-1984.
The process for preparing the current Draft Sludge Manage-
ment Plan is described in detail in Metro's plan, and will
16
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therefore only be summarized here. The following is a chrono-
logical order of reports and events leading to the plan:
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 Manage-
ment 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 issued its Draft Sludge Management
Plan for public review and comment. That plan included dis-
cussions 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, with
near-term 5-year and 1-year planning periods. The sludge
management plan includes long-range sludge management goals
focusing on soil improvement, silvicultural application, and
production and marketing of a composted sludge product. The
5-year plan (1984-1988) identifies utilization goals and a
financial plan for silvicultural activities, soil improvement,
composting, and development of storage basins. The 1-year plan
(1983) identifies specific projects where sludge will be applied
during 1983.
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 impor-
tance to this EIS:
17
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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 restric-
tions 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.
18
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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.
As a part of the planning and environmental evaluation
process, Metro established a citizens' sludge advisory
committee. Since August 1981, the Committee has met 29 times
for purposes of reviewing and discussing various aspects of
Metro's sludge management planning effort. All meetings were
announced in advance and were open to the public.
Additionally, a sludge project advisory committee was
created in Arlington for the purposes of reviewing and resolving
concerns associated with the application of sludge on the
Pilchuck Tree Farm. The Committee held 16 meetings, open to the
public, from December 1981 through February 1983.
Joint Metro and EPA public information meetings were held
May 3 and 5, 1983 in Seattle and Arlington, Washington. The
purpose of these meetings was to present the proposed project
and impact analyses to the public and to answer questions.
Public hearings on the Draft EIS were held May 17 and 19, 1983.
The Draft EIS comment period, the public meetings and
hearings held on the Draft EIS, the responses to oral and
written public comments included in the Final EIS, and public
comments received on the Final EIS (and included in EPA's
Record of Decision), fulfill EPA's formal public participation
responsibilities under the 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 1502.25; 40 CFR 6.300); 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 1506.2). Appendix H provides a review of federal,
19
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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.
20
-------
Chapter 2
Description of Alternatives
-------
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.
21
-------
Distribution
and
Marketing
12%
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
22
-------
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 in 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. From 1930 until 1980,
heat-dried sludge was sold by the Sanitary District to a broker
who in turn barged the sludge to Florida and sold it to citrus
farmers. At the time the program was discontinued in 1980,
approximately 300 dry tons per day were heat dried and barged.
The District presently produces 450 dry tons of sludge per day,
and almost all is used as a top dressing for the City of Chicago
landfill or for horticultural application (Gschwind 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 (Gschwind
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
23
-------
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) . DurTng 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.
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
managementfor this metropolitan areais 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.).
24
-------
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
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
25
-------
RICHMOND BEACH
TREATMENT
PLANT
CARKEEK PARK
TREATMENT
PLANT
WEST POINT
TREATMENT
PLANT
ALKI TREATMENT
PLANT
SLUDGE FORCE
MAINS
RENTON
TREATMENT
PLANT
SOURCE: METRO. 1983 a
FIGURE 2-2
Metro's Wastewater Treatment Plants
and Sludge Transfer Facilities
26
-------
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.
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.
27
-------
RICHMOND
BEACH
CARKEEK
PARK
RENTON
WEST
POINT
primary
sludge
primary
sludge
primary
secondary
sludges
Anaerobic
Digestion
Anaerobic
Digestion
sludge
Primary
Settling
t
digester gas
Reuse
sludge
digester gas
Reuse
digester gas
Reuse
Anaerobic
Digestion
sludge
Dewatering
-7*
centrate
ALKI
primary v
sludge '
sludge
Anaerobic
Digestion
/
\
digester gas \
/
Reuse
Composting
WIDCO
Cedar Hills
FIGURE 2-3
Flow Diagram of
Metro's Sludge Treatment and Disposal Processes
-------
SK.A 6 I T
C L A L L A M
J EFFEK&ON
G, f=l A V S
H A R. B O «.
"J^rlinaion
S N 0 H O M I S H
LANDFILL
©CEDAR HILLS
LANDFILL
4 GROCO
C- E
a L Uf I V IIIC \
&PACK FORESTv
L £ W / S
FIGURE 2-4
Existing Sites for Reuse of
Metro Sludge
29
-------
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).
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
supplying sludge to 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
30
-------
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.
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 program requires industrial dischargers to
meet certain limits established by Metro for the discharge of
toxicants and heavy metals into Metro's wastewater system.
Industries therefore have installed pretreatment processes to
reduce the quantities of metals and other pollutants 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
. 31
-------
Table 2-1. Metro's Past Sludge Disposal and Demonstration Programs
Project Name
Date
Purpose
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 Christmas 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 inprovement-landfill cover
Soil improvement-landfill cover
Soil inprovement-landfill cover
Soil improvement-park development
Soil improvement-park development
Soil improvement-turf enhancement
Soil improvement-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.
-------
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.).
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.
33
-------
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
Percent increase over
previous year 38.2
31.7 37.2 31.6
13.6 17.3 <15.2>1
Wet cubic yards of
digested sludge per
day (annual average) 142.6 197.8 210.0 247.5 231.5
Number of truck loads
per day (30 cu. yd.
capacity) 57788
Total dry tons of
digested sludge 7,380 10,200 11,590 13,590 11,525
NOTES: 1< > indicates a decrease.
SOURCE: Metro 1983g.
34
-------
CO
en
CO
Q
O
G-
o
O
O
I
O
Q_
co
a
200-
180-
160-
140-
120
100-
80
60
40
20
0-
Raw Sludge
Waste Activated Sludge
i ii ii ii i r i r i T i r i i i r i r
FMAMJJASONDJFMAMJJASO
1978 1979
i i
NO
IT
JF
i
M
ll
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
36
-------
to
80 -i
70-
60-
•5 > 50 -
CD CO
O Q
co W
Q
20-
10 -
0
1980
1985
1990
1995
2000
-550
- 500
- 450
T3
0)
— 400 t)
o>
01
- 350 Qi
- 300 45 !
- 250
- 200
- 150
— 100
— 50
CO
> 0
CD
FIGURE 2-7
SOURCE: METRO. 1983 a
Summary of Future Sludge Quantity
(Dry Tons and Wet Cubic Yards per Day)
-------
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
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), one component of municipal and industrial wastewater
sludge, come from sources which include industrial contribu-
tions, urban storm runoff and from corrosion of water distri-
bution 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, Part 261). Metro sludge has been tested
and is classified as a solid waste since it has none of the
characteristics of hazardous waste (as defined in 40 CFR,
Part 261) which include ignitability., corrosivity, reactivity
or extraction procedure toxicity- Since cadmium represents one
of the trace metals of concern, Metro has tested sludge to
determine extraction procedure toxicity. Based on EPA
regulations, if 1 mg/1 of cadmium is leachable from sludge, then
the sludge would meet the criteria for a hazardous waste. Metro
sludge has been found to contain leachable cadmium levels of
.0012 to .022 mg/1 (Mayer pers. comm.).
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).
38
-------
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 (mg/kg)
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
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 (itpn/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
West
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**
.16E9
.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
1,780.0
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
2.8
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*
Id*
.30E9
.24E8
.76E7
.60E2
<.3E2
.36E3
30.0
1/10 samples
0/10 samples
0/10 samples
SOURCE: Metro 1983a.
* Not detectable
**E = Exponential base 10.
39
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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
such as pesticides and herbicides (chlordane, DDT, endrin), and
PCBs. Metro's monitoring program results indicate that
concentrations of all but PCBs have been undetectable in Metro
sludge (see Table 2-3).
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). Anaerobic
digestion can reduce pathogens by 95-99 percent to meet this
requirement. 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.
40
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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 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
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 categories of sludge management previously men-
tioned, 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 alterna-
tives. Table 2-4 presents a summary description of the
alter-
natives and their present worth costs. The apparent least cost
alternative for the Renton plant is 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 costly alternative is soil improvement at
a public/private site located within 10 miles of the treatment
plant (Alternative 8a); the most costly alternative (also
Alternative 8a) is to transport to a soil improvement site
within a maximum distance (180 miles) of the treatment plant.
41
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Table 2-4. uuacnption of Long-term Sludgu Management Alternatives
Alternative
Description
Total Cost (Prc-aw.it
Mortji, Millions!
1 - Agricultural application
2A - Tank composting
(digested sludge)
2B Pile composting
-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 primary and thick- West Poir.1:: S23.3-45.3
ened secondary sludges frcm Renton (181 solidsl would be Renton: S~4 ..'-3''. • '•
trucked 45-190 miles, stored in lagoons and applied onto pri-
vate agricultural land using direct subsurface injection.
Land requirement 13 11,000 acres for 100« of sludge produced
annually.
Anaerobically digested sludge (18* solidsl would be conposted West Point: S46.9
using a Turbitol Company tank composter. Processing would be Renton. $87.4
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) West Point: $45.3-51.5
would be composted usmq pile composting. Sludge would be Renton: $82.8-87.5
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 '.ould sell for S2.50 per
cubic yard.
Primary and thickened secondary undigested sludges (18% solidsl West Point: 'J\
would be composted at the Renton plant, using a Turbitol Company Rcntan: $83.5
tank processing system. No anaerobic digesters would be JS'.-J
at the Renton plant. Composted sludge would !>? generated
at a rate of 150-190 cubic yards per day and would sell fcr
$2.50 per cubic yard.
Undigested (raw), dewatered sludge would be dried at the West Potr.t: Wi
Renton plant using direct/indirect rotary dryers to produce Renton: $115.3
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 386.00 per ton.
Undigested (raw), dewatered sludge would be thermally condi- West Poir.t:
tioned by a Zimpro low pressure oxidation process to forf Renter.:
a dry sludge cake. The sludge cake would be combusted IT.
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 West. Point: ~;A
at an industrial site in the Duwamish industrial area. Renton. $99.1
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 West Point: SA
and energy recovery prior to incineration. Renton: $108.8
5A Landfill 181 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 S10.50 to S25.00 pfir wet ton nf
West Point:
Her. ton:
S20.6-36.1
SB Landfill - 40% sludge
cake discosal
6 Ocean disposal
7A - Silvicultural
application private or
public forestlands with
Metro-owned demonstration
site
Anaerobically-digested and dewatered (40% solids) sludge West Point: S41.0-53.5
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 S10.50-S25.00
per wet ton of sludge.
Liquid anaerobically-digested sludge would be transferred West Poir.t: $32.3
to holding tanks and then onto larue 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: $29.5-34.1
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.
42
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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
Douglas-fir forestlands
7D - Silvicultural
application private or
public forestlands with
Metro-owned backup site
Anaerobically-digested sludge (18% solids) would be applied West Point: $36.4-36.8
at a rate of 10 dry tons per acre per year to 5,500 acres of Renton: $83.2-84.4
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: $94.5-95.7
(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 corcnercial thinnings at 20, 30, and 40 years.
This alternative would be the same as Alternative 7A except West Point: $31.6-36.2
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
SB Soil improvement
land owned by WIDCO
Cost Assumptions: Year 2000
at 7 5/8
Note: More detailed cost as
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.
design year truck transportation only. Electricity costs $.022-,
percent ENR 4500.
West Point: 18% solids -
$19.1-38.9
40% solids
$41.0-61.4
Renton: 18% solids
$72.1-83.3
40% solids
$73.2-89.4
West Point: 18% solids
$27.7
40% solids -
$46.6
Renton: 18% solids -
$76.6
40% solids -
$81.0
,028/kWh. Interest assumed
sumptions available in Metro's Sludge disposal and reuse cost-effectiveness evaluation
(Metro 1983b).
43
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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
Sludge Management Plan (1983g).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, six were dropped
from further consideration because of high costs, unacceptable
nonmonetary factors or a combination of the two. An additional
five 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 Tank composting (undigested sludge)
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
o 6 Ocean disposal
Deferred
o 1 Agricultural application
o 2A Tank composting (digested sludge)
o 2B-2 Pile composting - 40 percent solids
o 4B Coincineration with municipal solid waste
o 4C Multiple effect drying and incineration
Alternative 2C - Tank Composting (Undigested Sludge).
Metro rejected this alternative because no energy would be
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.
44
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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 because of the lack of beneficial
sludge reuse and opposition from landowners.
Alternative 5B - Disposal into Landfill, 40 Percent Solids.
Metro 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 6 - Ocean Disposal. Although ocean disposal is
the least costly alternative, it has been rejected because
federal and state regulatory agencies currently prohibit this
practice.
Alternative 1 - Agricultural Application. Metro deferred
this alternative because of the lack of suitable agricultural
land in western Washington and the cost of hauling sludge to
eastern Washington.
Alternative 2A - Tank Composting (Digested Sludge). This
alternative was deferred by Metro because of the higher costs
associated with tank composting vs. pile composting systems.
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.
Alternative 4B - Coincineration with Municipal Solid Waste.
Metro deferred this alternative because of technical, financial,
and operational uncertainties. The City of Seattle and King
County are presently evaluating the feasibility of constructing
a coincineration facility that could also conceivably receive
sewage sludge. Since the amount of sludge generated in the
Metro treatment facilities would be small when compared with the
City of Seattle and King County solid waste volume, the facility
would most likely be constructed and operated by either the City
or King County.
45
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Alternative 4C - Multiple Hearth Drying and Incineration.
This alternative was deferred because of the uncertainties
associated with an unproven technology.
The City of Los Angeles has initiated the Hyperion Energy
Recovery System (HERS) which is designed to utilize sludge to
generate energy. Metro will evaluate the success of that
project once it is on-line.
Detailed Description of Feasible Alternatives
Of the 18 initial alternatives evaluated by Metro, 7 were
recommended for additional evaluation. These alternatives were
as follows:
o 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 Douglas-fir forestry
- 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., composting,
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.
Composting. Sludge composting involves the aerobic
decomposition of ogranic constituents to a relatively stable
humus-like material. While sludge is not rendered totally
inhert by composting, in-vessel or static aerated pile
composting is considered by EPA to be a process to further
reduce pathogens.
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).
46
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Table 2-5. Costs of Feasible Alternatives
Alternative
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)
Alternative 7C
(Metro-owned Douglas-fir forest-
lands)
Alternative 7D
(Public/private forestlands with
Metro-owned backup site)
SOIL IMPROVEMENT
Alternative 8A
(Soil improvement of public or
private land)
Alternative 8B
(Soil improvement at WIDCO)
Capital Costs Year 2000 OiM Costs Present Worth Costs
($ million) ($ million)1 ($ million)1
Renton West Point Renton West Point Renton West Point
77.5 23.6 2.3 2.5 87.5 45.3
66.6 6.5 3.2-3.8 2.4-3.1 77.3-80.8 29.8-34.1
66.6 8.3 2.9-3.1 2.3-2.4 84.7-85.9 38.0-38.4
66.6 7.2 2.9-3.2 2.5-2.6 94.4-95.5 48.4-48.8
66.6 6.5 3.2-3.8 2.4-3.1 79.3-82.8 31.9-36.2
62.1 2.8 3.2-4.9 2.3-4.1 72.1-83.3 19.1-38.9
62.1 2.7 3.9 3.0 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 @ 7 5/8 percent; ENR of 4500;
accuracy within +50 to -30 percent.
SOURCE: Metro 1983b.
-------
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 a composting alternative (2B-1) from the
initial 18 alternatives. A detailed description of this
alternative follows.
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
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).
48
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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.
5. In general, year-round application schedules can be
maintained, minimizing storage needs and off-season
disposal demands.
Metro identified four feasible silvicultural application
alternatives: Alternative 7A, Public/private forestlands with
Metro-owned demonstration site; Alternative 7B, Metro-owned
poplar forestlands; Alternative 1C, Metro-owned Douglas-fir
forestlands; and Alternative 7D, Public/private forestlands 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
49
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application sites) and application vehicles. The application
sites would be located 30-95 miles from the Renton and West
Point treatment plants.
Alternative 7B - Metro-Owned Poplar Forestlands — 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 year, and after 7 years harvest the timber
for sale as a fuel source for generation 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 Douglas-Fir Forestlands —
Metro would purchase 26,500 acres of logged forestlands to grow
trees for timber revenues. 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 — 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 ir\
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 _in Bledsoe 1981) .
Using sludge for soil improvement includes storaging sludge
in lagoons, application, disking, final grading, and seeding.
50
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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 used 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.
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 then 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 or tilled into the soil using a caterpillar
tractor. A grass cover would be planted immediately after final
disking. Sludge application would occur 4 months of each year
at a rate of 15 to 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.
51
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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 Recommended Sludge Management Program
Goals of the Recommended Plan
Metro has defined six primary sludge management goals
relevant to various components of the recommended program.
These goals are to:
o Implement land application of sludge as the preferred
management strategy, including soil improvement,
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.
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
concentrations of potentially toxic or hazardous
substances entering the treatment plants by a more
stringent industrial pretreatment program or by treating
industrial flows separately -
In addition to these primary goals, Metro has identified a
goal specific to composting, silvicultural application, and soil
improvement as well as four secondary goals. These goals are
listed in Table 2-6.
Elements of the Recommended Plan
In-Plant Processing. Anaerobic digestion with medium
dewatering (18 percent solids) have been identified by Metro as
recommended in-plant processing.
Sludge Transport. Metro has identified truck transport as
the recommended transport mode.
Silvicultural Application. The first component of Metro's
plan includes application of sludge onto forestlands within a
distance of 30-95 miles from Metro's treatment plants.
52
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Table 2-6. Metro's Proposed Sludge Management Goals
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 treatanent facilities. Coordinate witn 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, suriace water
quality, and wildlife populations.
SOIL IMPROVEMENT
o Maintain existing contract with Washington Irrigation and Development Company (WTOCO) for sludge use in reclamation
of the strip mine site at Centralia.
o Implement additional soil improvement projects as available.
o Work with local parks departments to identify possibilities for using sludge to develop park sites.
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.
53
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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 mile from application
sites.
o Rehandling - Sludge pumps and nursing vehicles
(semi-trailer trucks with holding tanks for 6,000
gallons of sludge) 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. The nursing vehicles would return
to the sludge storage lagoons to refill.
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 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 1984-1988 planning period.
In addition to the Pilchuck demonstration project, Metro is
planning to initiate a 7-year program for operational scale
sludge utilization at Pack Forest to include:
o Demonstration site - 200 acres of established forest on
varied terrain, of which approximately 120 acres will
receive sludge.
o Energy plantation - two sites totaling 8 acres would
receive an annual application of one-half inch of sludge
to produce hardwoods for fueling steam plants.
o Wildlife/right-of-way demonstration - sludge would be
applied to approximately 4.6 acres of powerline
right-of-way (ROW) to demonstrate how sludge can improve
wildlife habitat in ROWs and prevent tree encroachment.
o King County site demonstration project - Metro will
pursue locating and establishing a 1,000 acre site
suitable for silvicultural operation and construction of
a sludge holding basin to hold a 1-year supply of
sludge.
54
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Metro will be required to carry out necessary SEPA and
public information processes for all aforementioned projects.
Soil Improvement. The second component of Metro's
recommended 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.
During 1983, Metro is utilizing five locations for soil
improvement:
o Cedar Hills Landfill
o Discovery Park
o Duvall Landfill
o Edmonds Community College
o WIDCO
Permits for all sites have been secured, and these sites
are considered an integral part of the 1983 sludge utilization
goal.
Production and Marketing of a Composted Sludge Product.
The third component of Metro's recommended plan is development
of a composted sludge product to be marketed and used as a soil
amendment, mulch, or fertilizer substitute. Metro has
identified one possible method of sludge composting, a pile
system 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. Metro will initiate several studies to assist in the
decision-making process:
o An economic study of ownership of vs contracting for the
compost facility.
o A market study to establish market capacity and price
for a composted product.
Metro has assumed that composting of sludge at the GroCo
facility in Kent will continue at a volume of 4,500 wet tons per
55
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year until 1988. After 1985, Metro's need for composting will
likely exceed the capacity of GroCo; at that time, Metro must
decide to engage another private contractor or construct a
Metro-owned composting facility.
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 1983 and 1984-1988 Utilization Goals
In addition to the long-term planning period, Metro's
sludge management plan includes a 5-year planning period
(1984-1988) and a 1-year (1983) planning period. Each is
designed to provide a more specific analysis of sludge
management projects and sites.
1983 Utilization Goal
Metro has identified seven permitted sludge application
sites to handle the projected 1983 sludge volume of 78,640 wet
tons (15,728 dry tons):
Silviculture
Pack Forest 3,676 wet tons
Soil Improvement
WIDCO 50,583 wet tons
Duvall Landfill 1,500 wet tons
Discovery Park 1,657 wet tons
Edmonds Community College 4,500 wet tons
Cedar Hills Landfill 4,196
Compost
GroCo 8,809 wet tons
TOTAL 74,921 wet tons
1983 Sludge Production 78,640 wet tons
If
Additional Capacity Required 3,719 wet tons
56
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1984-1988 Utilization Goal
Metro has established sludge distribution goals for each of
the years from 1984-1988. Table 2-7 presents the numerical and
percent distribution of sludge for silviculture, soil
improvement, and composting uses.
The Pilchuck Tree Farm demonstration project is a proposed
feature of the 5-year planning period. A description of the
demonstration project follows.
Pilchuck Tree Farm Demonstration Project. Metro has
initiated a cooperative program to apply sludge 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
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 1982c).
As part of the Pilchuck demonstration project, Metro
prepared the following documents:
o Hydrology report for Pilchuck Tree Farm Sludge
Application Site, November 1982 (Metro 1982a).
o Draft Plan - Pilchuck Tree Farm Demonstration Slduge
Application Project, March 1983.
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.
c 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.
57
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Ul
CD
Amount and Percent
Used
Silviculture
Soil Improvement
Conposting
TOTAL
Sludge Production
Additional Capacity
Required
1984
wt/yr
26,200
42,000
4,500
72,700
79,885
7,185
Table 2-7. Sludge
1985
% wt/yr
41.8 48,825 60
52.6 28,050 34
5.6 4,500 5
81,375
81,375
Distribution 1984-1988
1986 1987
% wt/yr % wt/yr jfe
.0 52,533 63.4 53,951 63.9
.5 22,000 26.6 22,000 26.1
.5 8,268 10.0 8,439 10.0
82,860 84,390
82,860 84,390
1988
wt/yr
64,600
24,857
9,943
99,430
99,430
%
65.0
25.0
10.0
SOURCE: Metro 1983g
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PILCHUCK TREE
FARM
S N 0 H O M I S H
C L A L L A
MASON
-------
Table 2-8 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 Sludge Project Advisory Committee, sludge would not be
delivered to the site on school days for 2 hours in the morning
and 2.5 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.
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 Sludge Management Plan. Chapter 3 is divided into two
separate impact analyses: an evaluation of the plan, and an
60
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Sludge
Application
Areas
Sludge Handling
Area
SOURCE: METRO.1982 d
FIGURE 2-9
Proposed Sludge Application
Sites and Facilities,
Pilchuck Tree Farm, Arlington, Washington
61
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Table 2-8. Estimated Truck Loads, Trips Per Day
and Hauling Days, Pilchuck Tree Farm
Demonstration Project
to
Storage
Alternative
One-million-gallon basin
Small basin (0.25 mg)
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 1982c.
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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, and
composting. The Pilchuck demonstration project impact analysis
consists of detailed project-level evaluation. Chapter 3 also
presents descriptions of the existing conditions of the planning
area in general, Pilchuck Tree Farm in particular, and
identifies mitigation measures to minimize adverse impacts.
63
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64
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Chapter 3
Environmental Setting and
Impacts
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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
composting, silvicultural application, and soil improvement;
3) Metro's preferred sludge management program; 4) the
no-project alternative; and 5) the proposed silvicultural
application project at the Pilchuck Tree Farm.
Impacts of Sludge Processing
All of Metro's proposed project alternatives, as well as
the preferred 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. Additional anaerobic digestion capacity would be
installed only at the Renton Treatment Plant.
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.
After January 1988, on-site sludge processing 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.
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Table 3-1. Energy Production for the Various
Project Alternatives
Alternative
Million BTUs Produced1
(Year 2000)
West Point
Renton
Alternative 2B
Alternative 7A
Alternative 7B
Alternative 1C
Alternative 7D
Alternative 8A
Alternative 8B
122,759
115,0142-129,9543
172,053 - 173,423
126,779 - 128,149
115,014 - 129.954
93,258 - 130,359
122,609
61,122
53,2752- 66,0993
109,567 - 113,800
64.293 - 68,256
53,275 - 66,099
29,153 - 64,262
59,376
NOTES: *A11 alternatives would produce more energy than would
be consumed.
2Assumes trucking maximum distance from treatment
plants.
3Assumes trucking minimum distance from treatment
plants.
SOURCE: Metro 1983b.
66
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Table 3-2. Projected Truck Traffic Frcm the Renton and
West Point Treatment Plants, 1980-2000
YEAR
a\
Renton treatment plant1,2
Trucks /day
Trucks/year
West Point treatment plant2
Trucks/day
Trucks /year
1980 1983 1985 1990
__ __ __ 5
1,871
7997
2,555 3,329 3,445 2,480
2000
7
2,352
7
2,652
1 Assumes sludge processing on-line in January 1988.
2 Assumes 57 percent of sludge volume from West Point for the year 1990 and 53 percent for year 2000.
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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.
Impacts of Metro's Recommended Alternatives
The following section of the EIS describes the existing
environmental impacts and mitigation measures associated with
sludge transportation, and with broad uses of composting,
silvicultural application, and soil improvement. Each of the 7
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 sludge management
plan, and 2) the proposed Pilchuck Tree Farm demonstration
project. The analysis below pertains to no-action for the
sludge management plan. 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 recommended program defines a number of specific
projects and 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
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 839 dry tons, or 5 percent of the 1983 projected quantity
of sludge, can be utilized at that site during the current year
(Machno pers. comm.).
68
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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.
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 13 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, 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 trucks are of leakproof design to prevent
leakage around the rear dump gates and are equipped with baffles
to prevent the sludge from moving during transit.
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.
Once sites are identified, the transportation impacts
associated with any of Metro's specific sludge reuse sites 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.
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Table 3-3. Projected Annual Fuel Consumption for Sludge
Trucking for Each Feasible Alternative (gal/yr)
ALTERNATIVE 1983 1990 2000
2: Composting 14,600 - 43,800 19,710 - 58,400 22,630 - 68,255
7: Silvicultural application
7A, 7D 43,800 - 138,700 58,400 - 184,690 68,255 - 215,715
7B, 7C 29,200 - 65,700 38,690 - 87,600 45,260 - 102,200
8: Soil improvement
8A 14,600 - 270,100 19,710 - 359,890 22,630 - 420,115
8B 109,500 - 138,700 146,000 - 184,690 170,455 - 215,715
Pilchuck 102,200 170,455 204,400
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Table
ALTERNATIVE
2:
7:
Composting
Silvicultural
application
7A, 7D
7B, 7C
3-4. Air
1983
1.0-3.
2.9-9.
4.4
Emissions From
HC
0 1
6 4
6
2000
.5-4.8
.5-14.9
.8
Trucking for
EMISSIONS
1983
2.7-9.
8.1-28
12.13
CO
3
.2
Each Feasible
(Ibs/day)
2000
4.2-14.4
12.6-43.8
18.9
Alternative
8.
25
37
NO
1983 K
3-29.7
.0-87.6
.45
2000
12.9-46.2
38.9-136.1
58.4
8: Soil improve-
ment
8A 1.5-15.0 2.4-23.3 4.7-45.8 7.4-71.4 9.6-179.8 14.9-280.5
8B (WIDOO) 7.6-9.5 11.8-14.7 23.2-29.0 36.3-45.2 74.1-94.0 115.7-146.6
Pilchuck demonstra-
tion project 6.4 19.8 70.5
SOURCE: EPA 1981b; Metro 1983a.
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Composting
Description of Existing Environment. The composting
alternatives considered by Metro would require location of
facilities in the Kent Valley industrial area or at some yet
undefined site.
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 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
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
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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 in 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.
Composted sludge will contain organic compounds (such as
organochlorine pesticides and polynucleararomatic hydrocarbons).
The compounds tend to adsorb to the sludge particles during the
sludge stabilization processes (Naylor and Loehr 1982) and have
very low water solubility, long half lives, and may be trans-
located in the food chain. Composting of sludge should not
appreciably change the levels of organic compounds although some
volatilization of petroleum hydrocarbons may occur (Babish
et al. 1981).
Metro has analyzed sludge from the West Point and Renton
treatment plants to determine the levels of some organic
compounds. Of 11 trace organics measured, only PCBs were found
in any detectable quantities (1.6 mg/kg).
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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 0.34
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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Studies of priority pollutants in sludge from 20 publicly-
owned treatment plants across the United States were conducted
by Naylor and Loehr (1982) . The studies indicated that when
sludge was applied at a rate of 11 dry tons per acre and tilled
into the top 6 inches of soil, the most concentrated organic
priority pollutant levels were one or two orders of magnitude
less than those resulting with recommended application rates for
agricultural pesticides. In all cases, levels of organics were
not considered to represent risks to public health based on LD,-g
values or the concept of "acceptable daily dose" for intake of
toxic chemicals.
Naylor and Loehr indicated that data are still insufficient
to determine the fate and transformation of organic priority
pollutants in soils and the uptake and translocation of such
chemicals in crops.
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.
Mitigation Measures.
o Design selected composting site with impervious surfaces
and a runoff collection system connected to the
municipal sewer.
o Design 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.
Meanwhile, Metro should provide adequate protection to the
consumer and user by initiating the following measures:
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o Provide adequate warning to consumers to use composted
sludge only on nonfoodchain crops.
o Conduct studies to examine the hazard posed by
pathogenic fungi such as Aspergillus fumigatus and
bacteria such as Micropolyspora facni and
Thermoactinomyces vulgaris.
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, PCS, 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.
Silvicultural Application
Metro (1983a) has determined that silvicultural application
is a cost-effective alternative if sites can be located from
30-95 miles from Metro's treatment plants. Counties within this
radius include all or part of 20 counties located as far east as
Yakima, west to Grays Harbor County, south to Skamania County,
and north to Whatcom County (Figure 3-1).
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 7C - Metro-owned Douglas-fir forestlands.
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Y A K I M A
LEGEND-
POTENTIALLY SUITABLE LANDS
SCALE
N
FIGURE 3-1. FOREST LANDS POTENTIALLY SUITABLE FOR SLUDGE APPLICATION
LOCATED WITHIN 95 MILES OF SEATTLE.
SOURCE-- U.S.6. S. TOPOGRAPHIC QUADRANGLES 8 ENVIRONMENTAL SERVICES, LAND DIRECTORATE.
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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.
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
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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 supply; 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.
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.
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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). A more detailed discussion of the effects of
sludge application on wildlife is presented in the Impact
Analysis of the Pilchuck Tree Farm Demonstration Project.
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 provide's a
broad overview of potential impacts in the Puget Sound area. A
detailed impact analysis of the Pilchuck demonstration project
follows.
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.
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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).
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.
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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.
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
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Table 3-6. Species Suitability Classes
Species Selection
Site Condition
Best Adequate Unsuitable
Recently cleared sites Cottonwood Pines Western hemlock
Poplar Redcedar
Douglas-fir Red alder
Sitka spruce
Young plantations " Pines Red alder
Existing forests Most conifers Pines Red alder and
most other
deciduous species
SOURCE: DOE 1982a
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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 to surface water from a
silvicultural application of sludge 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
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:
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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.
Pathogens and Organic Compounds — Anaerobically digested
sludge applied to forestlands will contain pathogenic organisms
and trace levels of organic compounds. Anaerobic digestion is a
process which reduces pathogens by 95-99 percent prior to land
application. Microbial pathogens (bacteria, viruses, and
parasites) have been measured in Metro sludge (see Table 2-3) in
varying levels. Bacterial survival in soil after application
may be as long as 225 days (Edmonds in Sopper and Kerr);
however, much of the die-off occurs within the first 45 days.
Virus survival in forest soils has been found to range from
110-170 days (Sagik et al. in Sopper and Kerr 1979) , while
survival of parasites tends to be considerably longer. Tables
3-20, 3-21, and 3-22 present an analysis of the quantities of
various materials which must be consumed at any one time to
cause salmonellosis, enterovirus infection, or ascaris/giardia
infection.
Discussions on the fate of organic compounds in forest
soils are presented 1) in the Geology and Soils, Assessment of
Impacts portion of the Pilchuck Impact Assessment; 2) in
Appendix B, Properties of Forest Soils, Organic Toxins; 3) as a
part of the discussion of the Composting alternative in Chapter
3. The discussion in Appendix B is specific to silvicultural
application of sludge.
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 — A complete investigation of the water
resources associated with a proposed site is necessary to allow
for inclusion of possible mitigation measures. Once the
resource values of each site have been determined, buffer
(nonapplication) zones, application rates and timing, facility
locations, and other project features can be modified to provide
sufficient protection to surface waters.
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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
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 imple-
mented.
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 year 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 year for 5 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.
Also, an evaluation of the collected data and recent
research findings should be performed and, if deemed necessary,
the duration of the monitoring phase should be extended.
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 — A buffer zone surrounding the sludge applica-
tion sites must be provided to protect area residents and land
uses from possible adverse impacts. While the DOE BMPs do not
include a recommended distance between application and residen-
tial areas, the distance should be based on factors such as
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terrain, prevailing wind direction, vegetation, and the method
of sludge application (i.e., tilling vs. spray application).
Soil Improvement
Description of Existing Conditions. Metro (1983a) has
defined the cost-effective distance of potential soil
improvement sites to be 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 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). Permits from both counties must be
renewed annually.
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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 both counties and DOE each month.
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. comra.).
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, Kent
Highlands, and Midway landfills. Sludge from Metro treatment
plants has in the past been used as top dressing at Cedar Hills,
Midway, and Duvall; plans exist to deliver approximately 5,700
wet tons of sludge to Cedar Hills and Duvall in 1983.
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
is appropriate to the intended subsequent use of the
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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.
In 1979, the EPA set forth Criteria for Classification of
Solid Waste Disposal Facilities and Practices; Final, Interim
Final and Proposed Regulations (40 CFR Part 257). In those
regulations EPA recognized that "... land application of parks
and forests and reclamation of poor or damaged terrain is a
desirable land management technique . . .," and that "appli-
89
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cation 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 lands used to grow crops. 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 food chain crops or crops
for animal feed. Soils in western Washington typically have a
pH ranging from 4.5-6.0, and must therefore be limed to adjust
the soil pH to the necessary 6.5 level.
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.
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
leaching 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., 15-120 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
90
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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.
Mitigation Measures. The DOE Best Management Practices
(1982a) provide some general 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 pro'jects.
Because of the concern for future uses of soil improvement
sites the following mitigation is suggested:
o Notify future property owners 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 Require Metro to 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
User Rates
Funding for the construction and operation and maintenance
of the sludge processing and application program would be
91
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provided by a combination of federal and state construction
grants, local revenue bonds, and monthly sewer service fees.
For approved capital facilities, for which funding is
available, federal grants can pay up to 75 percent of the
eligible cost, state grants up to 15 percent, and local funds 10
percent. If the project is classified as innovative and
alternative by the EPA, the federal grant can increase to 85
percent, the state grant becomes 9 percent, and the local share
decreases to 6 percent. In the past, Metro has sold revenue
bonds to finance the local share of the capital costs, and then
repaid these bonds using a portion of the Metro monthly charge.
Annual operation and maintenance costs are paid for by
Metro, and no grant funds are involved. Operation and
maintenance costs are paid for by a portion of the total monthly
sewer 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 sludge-related base monthly rate of
$3.20 per customer for construction, 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.
Table 3-8 presents a comparison of present worth costs for
sludge management associated with hauling and ultimate
application of sludge (costs not associated with treatment
plants). The table compares costs assuming 100 percent use of
sludge for silviculture, soil improvement, or composting vs. the
recommended program.
Table 3-9 presents a summary of costs for implementation of
Metro's preferred program during the first 6 years (1983 through
1988) .
92
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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
Composting $3.02 to $3.15
Silvicultural application $2.63 to $3.60
Soil improvement $2.22 to $2.90
SOURCE: Metro 1983a.
93
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Table 3-8. Comparison of Present Worth Costs for Sludge
Management Away from Treatment Plants; Single Alternative
Approach Versus Recommended Program Approach
(1988 Base Year; Millions of Dollars)
MINIMUM MAXIMUM
Silviculture (100%) 40.8 48.9
Soil Improvement (100%) 25.3 56.2
Composting (100%) 67.0
Recommended Program
Silviculture (65%) 36.1
Soil Improvement (25%) 11.3
Composting (10%) 4.0
Storage Basins (100% contingency) 1. 9
TOTAL 53.3
SOURCE: Metro 1983g.
94
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Table 3-9. Summary of Proposed Costs for Program Implementation:
Order-of-Magnitude Costing Basis with +50% to -30% Range
SLUDGE MANAGEMENT COSTS AWAY FROM THE PLANT, 1983 THROUGH 1988 1990 HAUL AND
HAUL AND 1990 TOTAL APPLICATION
PLANNING RESEARCH MONITORING HARD CAPITAL DISPOSAL BUDGET** O&M***
Silviculture 1,717,200 1,445,900 1,551,900 5,928,700 8,776,400 5,110,300 3,444,600
65% by 1988
Soil Improvement 656,000 -0- 24,700 -0- 6,453,400 1,264,400 1,152,800
25% by 1988
Composting 437,700 -0- * -0- 1,399,500 630,900 540,100
10% by 1988
Storage Basins 207,100 -0- 30,400 1,641,100 -0- 219,300 -0-
V£>
cn
TOTALS 3,018,000 1,445,900 1,607,000 7,569,800 16,629,300 7,224,900 5,137,500
* Compost monitoring costs included as a part of 38% supervisory allowance.
** 1990 Total Budget includes debt service.
*** 1990 Haul and Application O&M includes only direct site costs.
SOURCE: Metro 1983g.
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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 3-2.
A detailed description of the proposed demonstration project
appears as Metro's Draft Plan, and Pilchuck Tree Farm Demon-
stration Sludge Application Project.
This impact analysis consists of a brief overview of
impacts and evaluations of impacts of a no-action alternative,
construction-related impacts, and operation-related impacts.
Overview of Impacts of Pilchuck Project
Metro's proposal to construct a sludge storage basin and
access roads to apply sludge to 70 acres of forest, would cause
minor or moderate impacts at proposed sludge handling and
application areas on the Pilchuck Tree Farm.
Sludge application will cause changes in the physical and
chemical properties of the top 4-6 inches of soil (organic
content, nitrogen content, and occurrence of trace metals), will
be beneficial to the growth of Douglas-fir, and will cause an
increase in the nitrate levels in groundwater beneath the site
from 2.4 mg/1 to 8.3 mg/1. The increased nitrate levels will be
less than the 10 mg/1 EPA nitrate standard for drinking water.
Contamination of surface water will be unlikely given the
characteristics of the soil, slope, vegetative cover, and the
buffer zones proposed by Metro.
The transport of sludge would require a total of 365-520
trucks trips from Metro's West Point treatment plant to deliver
8,000 wet tons of sludge. That transport of sludge would cause
noise and occasional light and glare along the transport route
(Armstrong, Brakken, and Grandview Roads). Greater upkeep of
the road surface would be required on Armstrong Road because of
the increased traffic.
Sludge application would create odors during and imme-
diately after application. Foliage on the application site
would be coated with sludge until washed off by winter rains.
Some level of uptake of trace metals by plants is expected,
and some species of wildlife may ingest sludge during the course
of foraging and burrowing activities.
96
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Sludge
Application
Areas
Sludge Handling
Area
SOURCE: METRO. 1982d
FIGURE 3-2
Proposed Sludge Application
Sites and Facilities,
Pilchuck Tree Farm, Arlington, Washington
97
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The application site would be closed to public access for
13-20 months until pathogen levels approached background levels.
Given the physical characteristics of the proposed application
site, and the proposed mitigation measures, the risk to public
health is judged to be low. Approximately 0.05 percent of
sludge sprayed on the site is expected to be aerosolized.
Studies and monitoring will be carried out on-site by Metro
staff during and after application of sludge.
A number of mitigation measures relative to sludge
application have been presented throughout the impact analysis.
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.
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 3-10
presents the construction-related impacts associated with each
storage alternative and the access roads.
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
98
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10
10
Table 3-10. Construction-Related Impacts of Storage and Access Road Construction
Pilchuck Tree Farm
Storage Alternatives
Impacts
1 mg
Basin
0.25 mg
Basin
Reusable
Tank
Access
Trailer Roads
Mitigation Measures
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.
-------
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 3-3).
The two sites selected for the first applications of sludge
are underlain by a mixture of recessional outwash, Vashon till
and alluvial material (Figure 3-3). 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. Depth to bedrock is much greater than 4
feet and depth to the Vashon till is 50-75 feet.
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 (but not excessively) 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. The upper
layer provides sufficient percolation time to compensate for the
rapid permeability of the lower strata.
Soils on the Pilchuck site are similar to other glacially-
derived western Washington soils 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.
100
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30
FIGURE 3-3
Geologic Features
of the Pilchuck Site
=legend =
SOURCE: METRO 1983d
SLUDGE HANDLING SITE
DEMONSTRATION SITES
ALLUVIUM
VASHON TILL
SEDIMENTARY BEDROCK
VASHON RECESSIONAL OUTWASH
DOOO. STILLAGUAMISH SAND MEMBER
r?$f VASHON RECESSIONAL OUTWASH
v>V:V. SAND AND GRAVEL
101
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Productivity on the Pilchuck site is limited by the
availability of usable nitrogen (Staringer pers. conun.). 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 nitrogen 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 5 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.
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
102
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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 (ability of soil to
adsorb cations).
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.).
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.
103
-------
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
3-11). 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 Cation Exchange Capacity (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 3-11). 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 iri
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
must not bond with a stationary negatively charged particle or
anion. Bonding with mobile anions, such as nitrate, provide a
means for cation leaching in addition to free (unbonded) cation
movement. 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. Free cation movement is not expected
due to the abundance of stationary anions in the upper soils.
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
104
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Table 3-11. 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.
105
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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 3-12. 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 in 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
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 5 percent.
106
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Table 3-12.
TRACE METAL
Arsenic
Cadmium
Chronium
Copper
Lead
Mercury
Nickel
Zinc
Projected Loadings of Heavy Metals
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
per Hectare, Pilchuck Demonstration
KILOGRAMS/HECTARE
(kg/ha) 2
0.6
2.2
18.4
54.6
34.4
0.3
7.3
83.8
Project1
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.
-------
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 at least 33 years for 99
percent of the organic matter to decompose; 2 years for 8
percent. Faster rates of organic matter decomposition may be
expected on the Pilchuck site due to smaller application rates,
however, increased amounts of rainfall and cooler temperatures
may decrease the decomposition rate.
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) .
In the Draft Pilchuck Tree Farm report, Metro identified
the proposed site contaminant monitoring for the application
sites (Table 3-15). The monitoring program would include
bimonthly pre- and post-sludge application monitoring for the
parameters listed in Table 3-16 of this EIS and for two soil
stations shown in Figure 3-4. Control sites will also be
monitored (they have not yet been sited). The control sites
will provide a record of soil characteristics and changes with
respect to time and sludge application. Documentation of
108
-------
FIGURE 3-4
Surface Water Resources of the
Pilchuck Demonstration Project
Arlington, Washington
109
-------
microbial die-off will be necessary prior to permitting
uncontrolled access to the site (Metro 1983g).
Mitigation Measures.
o Design skid roads used to transport and apply sludge so
as to alleviate possible ponding of water or
concentration of surface runoff in areas close to
streams or other surface water.
o Monitor sludge 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 Select sludge application vehicle routes to minimize the
travel of the vehicle in the forest. This would help
prevent soil damage such as compaction.
o Do not apply sludge to soils where large 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 Flag 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 Refrain from applying sludge during a heavy rain to
reduce soil damage by the application vehicle and lower
the risk of groundwater contamination and surface
runoff.
o Conduct a field investigation of the tree density and
undergrowth uniformity within the two proposed stands
prior to siting of the soil monitoring stations. If
significant variations in tree density and undergrowth
exist, more than one soil monitoring station would be
necessary. If the tree stands are uniform, only one
station is needed and should be placed in an area
representative of the tree stand.
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.
110
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Assessment of Impacts. Depending on the sludge storage
alternative selected, the sludge application project would
require between 365 (66 days of hauling) and 520 truck trips
(104 days of hauling) 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 thexPilchuck Tree Farm.
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
basin. x
Emissions from the haul trucks and sludge pump will be
relatively minor compared to regional emissions, and will not
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 3-4). 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 1982c). 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 3-13 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 1982c). A complete
111
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Table 3-13. Hydrologic Data for Rock Creek, Kunze Creek, and
North Fork of the Stillaguamish River
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,
^rom WDOR Stream Catalog.
2 from USGS 1981.
-------
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 3-14 (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).
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 200-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).
113
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Table 3-14.
Water Quality Data for Reck 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 Col i form
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
Kunze Creek
Mean
(n = 7) Minimum
.021
1.01
.030
1.01
7.2
1.5
55
<.0001
<.011
.0017
<.0002
.0097
.03
<.006
260
66
440
.009
0.65
.014
0.53
6.7
0.5
44
--
<.001
.0016
<.0002
.0011
<.02
<.006
31
a
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 Crook 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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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 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. However, 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 3-15). The monitoring program would include
monthly pre- and post-sludge application monitoring for the
parameters listed in Table 3-16 for Rock and Kunze Creeks and
two springs located to the east and to the west of south site
(Figure 3-5).
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.
115
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Table 3-15. Pilchuck Tree Farm Soil and Water Quality Monitoring Program
SAMPLING STATION DESIGNATIONS
Primary groundwater stations
Test wells and spring
Neighbors wells
Other groundwater stations
Old Stand Lysimeters
Young Stand Lysimeters
Springs
Well #13 and Bunkhouse Well
Well #12
Rock and Kunze Creeks
Soil and Sludge
Old Stand
Young Stand
Lagoon Leakage Sump
Background Wells
NO. OF
STATIONS
4
4
5
13
PARAMETER GROUPS AND SAMPLING FREQUENCY1
GROUP 1GROUP 2GROUP 3
B&A Monthly
B 4/year
A I/year
L Quarterly
B Monthly
A 4/year
2
1
4
4
B&A Bimonthly
B&A Monthly
B&A Monthly
B&A Bimonthly2
B&A Bimonthly2
B&A Bimonthly
B Monthly
A Twice Monthly
F Weekly
L Quarterly
B Bimonthly
A Twice Monthly
L Quarterly
B&A Bimonthly
B&A Bimonthly
L Quarterly
L Quarterly
L Quarterly
B&A&L Monthly
1 Group 1 is all parameters. (No virus analyses for springs - inadequate flow.)
Group 2 is all conventional parameters, metals, and indicator bacteria, (coliform and
streptococci) - indicator parameters.
Group 3 is pH, EC, N02, and NO3, coliform (except lysimeters) and orthophosphate - tracer
parameters.
2 Metals organics and parasites analysed on alternate samplings.
LEGEND: B: Indicates frequency before sludge application in the vicinity of the station -
baseline monitoring.
A: Indicates frequency after sludge application in the vicinity of the station -
to continue for 12 months after application.
F: Indicates during first flush of water moving through the soil profile.
L: Indicates long-term follow up - for a 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 1983f.
NOTE: Subject to change depending on field conditions.
116
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Table 3-16.
Metro Contaminant Monitoring Project
Parameters
Conventional Physical and
Chemical Parameters
Organic N (Kjeldahl)
(sludge/soil only)
NH.-N
NO2+NO~
N0~
Total P
Orthophosphate P
Total solids
Volatile solids
PH
Turbidity
Conductivity
Fluoride
Organic Toxicants
Aldrin
Arochlor (PCB's)
Chlordane
DDT (4, 4'-DDT, ODD & DDE)
Dieldrin
Endrin
Lindane
Methoxychlor
Toxaphene
2, 4-D
2, 4, 5-TP (Silvex)
Parasites
Ascaris lumbricoides
Giardia lamblia
Others as identified in sludge
A nutrient analyzed with metals,
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 viruses
Polio viruses
Coxsackie B viruses
Eccho viruses
Coxsackie A viruses
Adeno viruses
Reo viruses
Unidentified viruses
SOURCE: Metro 198 3e,
117
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FIGURE 3-5
Surface and Groundwater
Monitoring Stations,
Pilchuck Tree Monitoring
Project
legend1
SOURCE: METRO. 1983d
• HOMES
•1 STORAGE BASIN
• MONITORING WELL
>*• PIEZOMETERS
O SHALLOW GROUNOWATER
MONITORING WELL
A SURFACE WATER SAMPLING
STATIONS
# SOIL/SLUDGE MONITORING
STATIONS
118
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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).
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 Adjustment of the 25-foot-wide buffer zone from the edge
of the bluff to the application area to ensure that a
minimum horizontal distance of 200 feet is maintained.
o Where possible, place the application road network 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, place
high-visibility markers along the edges of the
application sites to denote those buffer areas.
o Investigate and verify the structural integrity of the
Kunze Creek bridge.
o If the ground should freeze for an extended period of
time, cease sludge application 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 3-6). Hydraulic conductivity tests were conducted at
nine of the wells to determine the ease with which water is
transmitted through the aquifer. Table 3-17 presents the
results of the conductivity tests.
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
119
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O
Frvrear®\®Wil»on^ .
O
\
\ 1$
SOURCE: METRO 1982a
FIGURE 3-6
Well Location
Pllchuck Tree Farm,
Arlington, Washington
Groundwater Monitoring Wells
• 4-Inch Diameter
if 2-Inch Diameter
Domestic Water-Supply Wells
® Field Verified
O Unverified
: 5s Hydrogeologic Profile
Not Part of Site
120
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Table 3-17. 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
Elevation1
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
_2
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
Conductivity1*
(Feet per Day)
11
33
_3
-
-
-
-
-
-
-
—
No. 1 elevation set by at 1,000 feet. All other elevations were
established relative to that arbitrary reference elevation.
2Well No. 3 was dry.
3Hydraulic conductivity was not determined for the wells with no given
value.
''Results of hydraulic conductivity tests indicate groundwater movement
off-site to range between 11 and 33 feet per day.
121
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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.
The depth to groundwater is highly variable (13-57 feet)
but, in general, it is shallowest at the north and south ends of
the sites and deepest in the middle of the site (Table 3-17)
(see Appendix F for a hydrogeologic profile of the site). Metro
studies estimate the seasonal fluctuation of the water table 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 3-15). 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 water 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.
Henry and Cole (1983) have estimated a NO..-N loss of 75 pounds
per acre for the first year following sluage application (see
Appendix B for a detailed description of nitrate leaching).
Assuming a worst-case situation, approximately 5,400 pounds of
N03~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
122
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on the surface of the aquifer with little mixing below 5-10 feet
of saturated depth (Keeley pers. comm.). The contaminated zone
deepens as the distance from the source increases; however, the
NO.J-N concentration tends to become diluted as a result of
dispersion and diffusion.
Assuming a worst-case condition, based on University of
Washington data, CH2M Hill calculated that sludge could
contribute 5.9 mg/1 N03-N beneath the site during the months of
September through December during the year of application and
for approximately 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 data were collected 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
concentrations are expected to decrease significantly in the
years following application as nitrate leaching diminishes. The
time period required to return to background nitrate levels will
be influenced by the nitrogen demand of vegetation and the
movement of groundwater away from the site.
Even though NO.,-N concentrations would temporarily 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 3-17).
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.
Groundwater volume, flow rate, and direction are not
expected to be affected from a 1-inch application of sludge.
123
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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 capture
any material that might accidentally leak from the basin.
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.
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 amount to approximately 200,000 gallons per year, which
would be spray applied during the summer months when nutrient
and moisture demand are greatest. An estimate of 100 pounds of
N03~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 3-15,
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. Monitoring wells will also be used to
verify groundwater flow direction and rate.
Metro's proposed monitoring response plan would include
action in the event groundwater from monitored domestic wells or
site monitoring wells reached 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 Determine the best location for the rainwater spray
application site to avoid any possible downstream
contamination.
o Establish a monitoring well to test groundwater
immediately downslope of the spray application site.
124
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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.
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 1982c). Inventory work
would include an intensive survey to determine seasonal and
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
125
-------
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.
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 while 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 3-18), 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
126
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to
Table 3-18. Metal Concentrations (x±S.D.) in Plant Species Found on
Sludge-Ttreated and Control Areas at Pack Experimental Forest
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
±6.8
16.1
±3.7
6.9
±5.6
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
10.8
9.6
±3.9
5.94
±1.2
8.87
±1.0
5.6
±0.8
10.7
±0.5
- puftj
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
0.6
±0.3
1.5
±0.6
2.2
±0.l|
1.5
±0.6
4.8
±1.8
2.1
±0.8
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
0.09
±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
iO.09
0.06
±0.02
0.25
±0.12
1.22
±0.42
0.10
±0.03
2.92
±0.67
SOURCE: West et al. 1981a.
-------
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.
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.
The role of wild animals as potential vectors of disease
organisms is also of concern. Wild animals may serve as
mechanical vectors of microoganisms, become actively infected,
amplify the organism, or store the organism without
amplification. Disease organisms potentially transmitted from
sludge-amended land by wildife include Giardia spp. and other
parasites, cestodes, nematodes, and bacteria such as coliforms
and Salmonella (Prestwod in Bitton et al. 1980). Little
information is available on actual transmission of disease
agents from sludge-amended land by wildlife; however, studies
conducted on domestic animals grazing on sludge-amended pastures
and wastewater-irrigated fields has indicated that animal
disease is mostly attributable to contamination by untreated
sewage and sludge (Yeager in Bitton et al. 1980).
In all likelihood, some or all of the above-mentioned
impacts would occur at the Pilchuck site. Continued research in
128
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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.
o As proposed by Metro, terminate sludge application on
the 70-acre site in mid-March to minimize the impact of
sludge application on nesting birds.
o Initiate studies to define the importance of wildlife as
vectors of disease organisms resulting from application
of sludge to forestlands.
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.
129
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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 complete stand history for both sites is presented in
Appendix C.
Productivity on both sites is limited by nitrogen 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. Th"e 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 was sprayed with the fungicide Bravo 500 in June
1982 to control the fungus.
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.
130
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Assessment of Impacts.
Timber and Understory Growth — Application of sludge to
forestlands is expected to increase the growth rates of managed
stands. Potential increases in tree growth following sludge
application are due primarily to the large influx of nitrogen.
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, usually occurring 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.
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.
131
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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 ppra.
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.).
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 1982c) . A
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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, greater 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 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. 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.
o Implement mitigation measures previously described for
surface water impacts.
o Analyze stream water quality bimonthly in terms of EPA
(1976b) criteria for protection of freshwater organisms.
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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 3-7).
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.
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.
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UtltMlf
flltllltlff \ltuilf" \IMIIMff \1MMM"
11 it It it t(M \tllitilii' Viiiitmif Utltillf/r it
SOURCE: SNOHOMISH COUNTY. 1982
FIGURE 3-7
Zoning in the
Project Vicinity
p=legend=
RC RURAL CONSERVATION
AGRICULTURE 10 ACRE
FORESTRY AND RECREATION
FORESTRY
135
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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 3-8).
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.
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 Sludge Project 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
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V
%
SOURCE: ARLINGTON AREA PLAN, SNOHOMISH COUNTY. 1975
FIGURE 3-8
Projected
1990 Land Uses
=legend
R RURAL (.2-.4 DU/A)
PARK/OPEN SPACE
AGRICULTURE (1DU/10A)
COMMUNITY FACILITIES/SCHOOLS
FORESTRY
137
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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 — The Snohomish County Assessor's Office
has provided a written opinion to the tree farm that property
values surrounding the tree farm are unlikely to be affected by
the demonstration (Sludge Project Advisory Committee minutes
October 1982) (see Appendix J).
Mitigation Measures.
o Following initial sludge application, determine the need
to increase the buffer zone between residences on the
north and the application site, if odors, noise, or
aesthetics are a problem.
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
3-9). Table 3-19 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.).
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^CENSUS T
534
PACT
Smokes Rd. /
CENSUS TRACT
535.02
liSO' 2500' N
FIGURE 3-9
Census Tracts in the Vicinity
of the Pilchuck Tree Farm
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Table 3-19. 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
SOURCE: 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
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 3-10
(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
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SOURCE: SNOHOMISH COUNTY PLANNING DEPARTMENT. 1982
FIGURE 3-10
New Residential
Development in the
Project Vicinity
NEW RESIDENTIAL DEVELOPMENT
1081
NEW RESIDENTIAL DEVELOPMENT
1080
NEW RESIDENTIAL DEVELOPMENT
1079
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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 basins 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 (Figure 3-11).
The 1981 average daily traffic (ADT) for State Route 530 was
5,400 vehicles, and State Route 9 ADT was 2,500 vehicles (Metro
1982c).
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 (Figure 3-12).
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 (Figure 3-12) .
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 Pilchuck
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
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SKAGIT COUNTY
SNOHOMISH COUNTY
PILCHUCK THEE FARM
ARMSTRONG TRACT
;:|iyStillaguamiih
LEGEND
Roads
limn Haul Route
Mountlake
Terrace
SNOHOMISH COUNTY
i
-------
PILCHUCK
Unfoad at handling
« area and
return /
via \
Brakken x
.»*
FARM
ARMSTRONG
•••in Site Boundary
Roads
-1—| Arlington
From: Metro I983g.
FIGURE 3-12
Local Haul Route
145
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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 Sludge Project 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 -
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
acceleration 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 Sludge Project 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.
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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 (Sludge Project Advisory Committee pers.
comm.).
o Erect road signs on Armstrong Road warning motorists of
wide-load vehicle use of the road.
o Coordinate with Snohomish County to establish periodic
cooperative maintenance checks and repairs to Armstrong
and Brakken Roads.
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.
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.
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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. 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
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 Sludge Project Advisory
Committee. The odor of sludge would generally be most
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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 (Sludge Project 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 1982c).
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
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 Reduce sludge odor drift by spraying the sludge onto the
forest on calm days.
o Reduce noise impacts from construction and operation
activities by restricting the use of heavy equipment to
daytime hours, between 8 a.m. and 4 p.m.
o If necessary, increase the buffer zone on the northern
boundary of the north demonstration site.
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Recreation and Access
Description of Existing Environment. The Pilchuck Tree
Farm is used for both passive and active recreational activities
including 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.
Three-fourths of a mile 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
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 Sludge
Project Advisory Committee. The amount of land closed by the
project would constitute less than 10 percent of the Armstrong
Tract and less than 1 percent of the entire tree farm (Sludge
Project 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 will 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 project because of the 200-foot
150
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buffer zone and the 0.75-mile distance from the demonstration
area to Cottonwood Terrace.
Mitigation Measures.
o Post and fence area surrounding application sites (Metro
has already committed to this measure), sludge handling
facilities, and equipment storage areas to prohibit
unauthorized entry and use.
o Erect message or pictorial warning signs for children
(Metro has already committed to this measure).
o Notify local residents by letter to inform them that
certain areas of the tree farm will be closed until
further notice.
Cultural Resources
Appendix E of this EIS presents the results of field
studies carried out by the University of Washington, Office of
Public Archaeology and related correspondence.
Several artifacts were found on the proposed sludge
application sites; therefore, the Office of Public Archaeology
has recommended a number of mitigation measures. A response to
the findings of the State Historic Preservation Office is
contained in Chapter 7.
Mitigation Measures.
o As recommended by the State Office of Archaeology and
Historic Preservation, a professional archeologist will
walk all newly exposed access roads or skidder roads to
locate any potentially significant archeological
remains.
o If during construction of the sludge storage basin
cultural remains are encountered, work will be halted
and the State Office of Archaeology and Historic
Preservation contacted.
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
151
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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 equipment or a
contaminated area.
Microbial Pathogens — Microbial pathogens found in sludge
include bacteria, viruses and parasites. Figure 3-13 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.
Bacteria — 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 Bitton 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
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 EatonviTTe, 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).
152
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Figure 3-13. Possible Pathways of Microbial Transport Out of
Sludge in a Silviculture Application
Surface
Water
co
Digested Sludge
v/
Application (Spray)
i
Aerosols
Surface^—
Runoff
Trees, Undergrowth, Soil, Litter Layer
-7 Animals
Insects
(Vectors)
v
Sub-Surface Soil
J
Groundwater i
-------
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 3-20 for an example using salmonellosis).
Viruses — 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 adsorEed 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. in 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 1983c).
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 3-21 for an
example using enterovirus infection).
Parasites — 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
154
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Ul
Table 3-20. 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 Immediately
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
NA"
>70 Ibs
>880 gal
>880 gal
Time
NA4
3
>4.8
>4.8
2
yrs
yrs
NOTES: •'•Quantity of air, sludge/soil or water which must be consumed at one time to result in
intake of minimum infectious dose.
2Tinte 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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Ul
Table 3-21. 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 Immediately Three Months After
Following Application Application
Aerosols
Sludge-soil-litter
Surface water
Groundwater
Quantity1
>400M3
0.1-1 Ib
400 gal
>400 gal
Time2 Quantity1 Time2
>20 days NA NA
3 1 Ib 3
2.2 yrs >400 gal >2.2 yrs
>2.2 yrs >400 gal >2.2 yrs
One Year After
Application
Quantity1 Time2
NA NA
>1 Ib 3
>400 gal >2.2 yrs
>400 gal >2.2 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 20M3 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.
-------
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
3-22 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; Sludge
Project Advisory Committee Minutes October 1982) . Figure 3-14
shows the possible heavy metal transmission routes from forest
sludge application to humans (Metro 1983d).
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 3-23 for an example using cadmium).
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 3-15.
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
157
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Table 3-22. Quantities Which Must be Consumed at One Time to Result in Ascaris/Giardia Infection
and the Time Required for an Average Adult to Consume that Quantity
en
Aerosols
Sludge-soi1-1itter
Surface water
Groundwater
During and Immediately Following
Application
Three Months After
Application
ASCARIS
Aerosols
Sludge-soil-litter
Surface water
Groundwater
Quantity *
No data1*
>.25 lb/4 oz
>100 gal
>100 gal
Time2 Quantity1
MA
3 >.25 Ib
>200 days >100 gal
>200 days >100 gal
Time2
3
>200 days
>200 days
GIARDIA
No data"
>2.2-5.5 Ibs 3
>1,000-2,500 gal >5.5-13.7 yrs
>1,000-2,500 gal >5.5-13.7 yrs
No data1*
>2.2-5.5 Ibs 3
>1,000-2,500 gal >5.5-13.7 yrs
>1,000-2,500 gal >5.5-13.7 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.
**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 3-23.
Daily Human Consumption Necessary to Cause Health Problems
from Cadmium or Lead
Cn
'
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.
Multiple of
Normal Consumption
(6)
(6)
(6)
> 160
^160
(7)
(7)
(7)
(7)
Lead
Quantity (2)
0.001 Ibs.
0.007 Ibs.
0.016 Ibs.
;>40 gal.
^40 gal.
unlimited
0. 18 Ibs.
0.83 Ibs.
0. 1 1 Ibs.
0. 18 Ibs.
Multiple of
Normal Consumption
(6)
(6)
(6;
>80
^-80
infinite
(?;
(7)
(7)
(7)
(1) Cd toxicity based on 200 ug daily ingestion from all sources for 50 years
(2) Pb toxicity based on 150 ug daily ingestion by children over an undetermined period. Adults can safely
consume twice as much lead as children.
(3) Assumes a mixture of 1 part sludge to 2 parts soil on a dry weight basis or 1 inch of sludge mixed with
1/4 inch of soil.
(4) 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.
(5) Based on 1.6 mg/kg Cd and 21 mg/kg Pb avg. measured content in soil at Pilchuck Tree Farm.
(6) It is not expected that anyone will consume soil from the demonstration area.
(7) Cannot calculate because normal intake not known.
SOURCE: Metro 1983d.
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Figure 3-14. Pathways of Metals Transport From Sludge
in a Silvicultural Application
Digested Slodge
T
Surface
Water
Spray Applicatic
I
-Surface^—
Runoff
Trees, Undergrowth, Soil, Litter
Fish
Subsoil
Animals
Insects
Figure 3-15. Pathways for Organic Toxicant Transport From Sludge to
Environmental Compartments in Silviculture Application
Edible
Mushrooms
Berries
Other plants
Sludge
*'
Application-
Soil-Trees-Litter-Shrubs
I
Volatilization
Groundwater
(jondensation Off-Site
water, soil, food crops
SOURCE: Metro 1982c.
160
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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 3-24).
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.
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.
161
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Table 3-24. 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
Cements
Aerosols
Soil
Unknown
15 g (0.6 oz)
No data
Used 1.2 ppm PCBs in soil and
as standard
.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 recommended EPA
criteria. Based on work of Kaldriko and
Nelson 1979, surface erosion and subsequent
surface water contamination should be unde-
tectable.
Sludge maximum PCBs levels are four times
lower than EPA-reconmended 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-recommended
criteria. However, no detectable leaching of
PCBs to groundwater is anticipated.
^•Cattle 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.
162
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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).
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
163
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of and exposure to aerosols can be minimized by initiating the
following practices:
o Creating of a buffer zone around the application site.
o Applying 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 500-foot buffer zone
between the application site and the residential area to the
north. Additionally, Metro has indicated that a weather
monitoring facility will be established on-site to determine
wind direction and speed. The sludge operation plan being
developed by Metro will 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 are
projected to be minor. The effects of forest canopy on aerosol
production and drift are not well understood (Edmonds and Mayer
in 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.).
164
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Mitigation Measures. A number of mitigation measures for
surface water and groundwater impacts were previously described.
Metro has committed to the following measure:
o Conduct sludge spraying closest to the residential area
only on days of no wind or when the prevailing wind
direction is away from the residential areas.
With regard to public use of the site following sludge
application, the following measure will be implemented by Metro:
o Conduct studies of mushrooms, edible berries, and
wildlife at the site to determine the need for limiting
public activities on the site at least 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 developing
site operation procedures and developing procedures for clearly
delineating unit areas designated for sludge application (i.e.,
marking boundaries for each truckload of sludge).
As a consideration to ensure that viruses, bacteria, and
toxicants have no effect after the 5-year site monitoring period
proposed, it is recommended that Metro initiate the following:
o Extension of the 5-year monitoring program in the event
monitoring data indicate the presence of sludge-related
viruses, bacteria, or other organisms.
In order to further limit the access to the application
site, particularly by children and large domestic animals, Metro
has indicated that the following measure will be carried out:
o Installation of a 6-foot-high chainlink fence along the
northern boundary of the application site.
165
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166
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Chapter 4
Coordination
-------
Chapter 4
COORDINATION
Introduction
EPA's procedures for implementation of NEPA require that
EISs discuss 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
Sludge Management Plan and the Pilchuck demonstration project.
Key EIS public participation activities 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
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 project's initial
project "kickoff" and scoping meetings.
Scoping Meetings
Joint scoping meetings were held by Metro and EPA in
December 1981. Metro staff explained their general 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 Responsive-
ness Summary was prepared and distributed in April 1982.
167
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Notice of Intent
On November 6, 1981, EPA's Notice of Intent to prepare an
EIS was published in the Federal Register.
Citizens' Advisory Committee Meetings
A 16-member Citizens' Advisory Committee was established by
Metro and approved by EPA for the purpose of actively involving
representatives of the general public, public agencies, and
environmental and economic interest, in the sludge management
planning process. As of May 1983, the advisory committee had
met 29 times.
A 19-member Sludge Project Advisory Committee was also
established in Arlington to provide input into the plan to apply
sludge on forestlands at the Pilchuck Tree Farm. The committee
held 16 meetings from December 1981 through February 1983.
Meetings for both committees were publicized and were open to
the public.
Presentations to Sludge Advisory Committees
On February 15 and 16, 1983, the EIS consultant presented a
report on the EIS to the Sludge Project Advisory Committee in
Arlington and to the Metro Sludge 201 Citizens' Advisory
Committee. The impacts associated with the proposed long-range
alternative and Pilchuck project were identified and discussed.
Comments and Suggestions Reviewed During Preparation of the EIS
During the Metro planning period, the Sludge Project
Advisory Committee developed a list of 17 concerns associated
with Metro's proposed sludge application project on the Pilchuck
Tree Farm. These concerns were incorporated into a "checklist"
to ensure that the topics were addressed in the Draft and Final
EISs.
The Metro Sludge 201 Citizens' Advisory Committee and the
Sludge Project Advisory Committee (Arlington, Washington)
reviewed the Sludge Management Plan and EIS and provided
recommendations and statements of position to Metro (see
Appendix I).
Public Meetings and Hearings on Draft Plan and EIS
Public information meetings and hearings were held by Metro
and EPA in May 1983 to receive comments on Metro's Draft Sludge
Management Plan and EPA's Draft EIS. Legal notices of the
information meetings were prepared by Metro.
168
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Two Metro/EPA public information meetings were held:
May 3, 7:30 p.m., Federal Building, Second Avenue, Seattle.
Chaired by Tyra Elliott, Metro Public Information Staff.
Approximately 20 persons attended.
May 5, 7:30 p.m., Arlington Middle School, Arlington,
Washington. Chaired by Earl Rice, Metro Public Information
staff. Approximately 60 persons attended.
Two Metro/EPA public hearings were also held:
May 17, 1983, 7:30 p.m., Federal Building, Seattle.
Co-chaired by Beth Bland, Metro Council Water Quality
Committee chairman and Richard Thiel, EPA/Region 10 Chief
of Environmental Evaluation Branch. Approximately 12
persons attended.
May 19, 1983, 7:30 p.m., Arlington Middle School,
Arlington, Washington. Co-chaired by Beth Bland and
Richard Thiel. Approximately 60 persons attended.
Persons attending the public meetings and hearings gave
oral and written testimony on the draft plan and EIS.
Transcripts of the public hearings are available for public
review at the EPA Region 10 offices. Metro has distributed a
Responsiveness Summary which includes responses to the most
frequently received comments.
Written Comments on the Draft EIS
EPA announced the availability of the Draft EIS in the
Federal Register on Friday April 15, 1983. The 45-day review
period extended until May 31, 1983. Agencies, organizations,
and individuals were encouraged by EPA to submit written
comments on the -EIS.
Copies of all written comments received on the Draft EIS
are contained in Chapter 7 of this Final EIS, together with EPA
responses to each comment. These letters include those
addressed to EPA, as well as those addressed to Metro.
Schedule for Final EIS Review
The Final EIS will have a 30-day review period, during
which time EPA will receive and consider written comments. The
mailing list for the Final EIS is shown in Appendix K.
Over 300 copies of the Final EIS are being distributed for
citizen and agency review and comment.
169
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170
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Chapter 5
List of Environmental Impact
Statement Preparers
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Chapter 5
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
efforts with other EPA Region 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.,
Wildlife Biology. As staff 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.
171
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Area of EIS Responsibility. Project coordinator; sludge
management alternatives, public participation and wildlife
impact analysis.
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
siIviculture 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.
172
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Robert Sculleyf 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.
Area of EIS Responsibility. Air quality and traffic impact
analysis.
Blazier Engineers:
Richard Gilmore, P.E., B.S, and M.S., Civil Engineering.
Civil engineer specializing 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
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Chapter 6
Bibliography
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Chapter 6
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., Risk 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 in C. S. Bledsoe, ed.,
Municipal sludge application to Pacific Northwest
forest lands. College of Forest Resources, University
of Washington, Seattle, WA.
Babish, J. G., D. J. Lisk, G. S. Stoewsand and C. Wil-
kinson. 1981. Organic toxicants and pathogens in
sewage sludge and their environmental effects. Special
Report No. 42.
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., Ri Chaney, and B. Mulhern. 1982. Heavy
metal concentrations in earthworms from soil amended
with sludge. J. Environ. Quality 11(3):381-385.
175
-------
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.
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. DavTdson, 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
Science, Ann Arbor, MI.
Clark, D. R., Jr. 1979. Lead concentrations: bats vs.
terrestrial small mammals collected near a major
highway. Environ. Sci. Technol. 13:338-341.
176
-------
Cole, D. W., and D. W. Johnson. 1979. The cycling of
elements within forests. Pp. 185-198 in P. E. Heilman,
H. W. Anderson, and D. M. Baumgartner, eds., Forest
soils of the Douglas-fir region. Washington State
University Coop Extension Service, Pullman, WA.
Cooper, R. C., and C. G. Golueke. 1979. Survival of
enteric bacteria and viruses in compost and its
leachate. Compost Science/Land Utilization v:2£
•3 O » *
Dacre, J. 1980. Potential health hazards of toxd or-
ganic residues in sludge. Pp. 85-102 in G. Bitt_n,
B. L. Damron, G. T. Edds, and J. M. Davidson, eds.,
Sludge-health risks of land application. Ann Arbor
Science, Ann Arbor, MI.
Edmonds, R. L. 1979. Microbiological characteristics of
dewatered sludge following application to forest soils
and clearcut areas. Pp. 123-136 in W. E. Sopper, and
S. N. Kerr, eds., Utilization of municipal sewage ef-
fluent and sludge on forest and disturbed land.
Pennsylvania State Univ. Press, University Park, PA.
Edmonds, R. L., and D. W. Cole. 1976. Use of dewatered
sludge as an amendment for forest growth. Center for
Ecosystem Studies, College of Forest Resources, Uni-
versity of Washington, Seattle, WA. Volume 1, 112 pp.
. 1977. Use of dewatered sludge as an amend-
ment for forest growth. Center for Ecosystem Studies,
College of Forest Resources, University of Washington,
Seattle, WA. Volume 2, 129 pp.
. 1980. Use of dewatered sludge as an amend-
ment for forest growth. Center for Ecosystem Studies,
College of Forest Resources, University of Washington,
Seattle, WA. Volume 3, 115 pp.
Edmonds, R. L., and K. P. Mayer. 1981. Biological
changes in soil properties associated with dewatered
sludge application. Pp. 49-59 in C. S. Bledsoe, ed.,
Municiple sludge application to Pacific Northwest for-
est lands. College of Forest Resources, University of
Washington, Seattle, WA.
Energy Research and Development Administration. 1976.
Sludge management disposal and utilization. Prepared
for Third National Conference on Sludge Management
Disposal and Utilization.
177
-------
Erickson, H. D., and G. M. Lambert. 1958. Effects of
fertilization and thinning on chemical composition,
growth and specific gravity of young Douglas-fir.
Forest Science 4 (4):307-315.
Epstein, E. 1973. The physical processes in the soil
as related to sewage sludge application. University
Workshop, University of Illinois. U. S. Environmental
Protection Agency.
Environmental Managment Services. 1973. Lands Directorate,
Land Use Map, Puget Sound Region. Ottawa, Canada.
Frank, Allen. 1978. Mining waste, mine reclamation and
municipal sludge. Sludge Magazine July-August:23-27,
1978.
Hammond, P- B., and R. P. Belilies. 1980. 2nd ed.
Metals. Pp. 409-468 in J. Doull, C. Klaasen, and M.
Amdur, eds., Casertett and Doull's toxicology - The
basic science of poisons. Macmillan, New York.
Harding, H. J., R. E. Thomas, D. E. Johnson and C. A. Sorber.
1980. Environmental monitoring of sites conducting land appli-
cation of liquid sludge. EPA-600/S1-81-028. Health Effects
Research Laboratory, U. S. Environmental Protection Agency-
104 pp.
Harris, A. R. 1979. Physical and chemical changes in
forested Michigan sand soils fertilized with effluent
and sludge. Pp. 156-161 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.
Heilman, P. E. 1979. Minerals, chemical properties and
fertility of forest soils. Pp. 121-136 in P- E. Heil-
man, H. W. Anderson, and D. M. Baumgartner, eds.,
Forest soils of the Douglas-fir region. Washington
State Univ. Coop Extension Service, Pullman, WA.
Heilman, P. E., and S. P. Gessel. 1963. Nitrogen re-
quirements and the biological cycling of nitrogen in
Douglas-fir stands in relationship to the effects of
nitrogen fertilization. Plant and Soil 18:386-402.
Helmke, P. A., W. A. Robarge, R. L. Korotev, and P. J.
Schomberg. 1979. Effects of soil-amended sewage sludge
on concentrations of elements in earthworms. J.
Environ. Qual. 8 (3) : 322-327.
Henry, C., and D. W. Cole. 1983. Use of dewatered sludge
as an amendment for forest growth. Center for Eco-
system Studies, College of Forest Resources, University
of Washington, Seattle, WA. Volume 4.
178
-------
Hubbard, S. 1981. Seattle Metro sludge management op-
tions. Pp. 17-26 in C. S. Bledsoe, ed., Municipal
sludge application to Pacific Northwest forest lands.
College of Forest Resources, University of Washington,
Seattle, WA.
Johnson, D. W., and D. W. Cole. 1980. Anion mobility
in soils: relevance to nutrient transport from for-
est ecosystems. Environment International 3:79-90.
Kirkham, M. B. 1974. Disposal of sludge on land: ef-
fect on soils, plants, and ground water. Compost Sci-
ence 15(2) :6-ll.
Lee, G. F., and R. A. Jones. 1978. Chemical agents of
potential health significance for land disposal of
municipal wastewater effluents and sludges. Pp. 27-59
in Bernard P. Sagik, and Charles A. Sorber, eds.,
Risk assessment and health effects of land application
of municipal wastewater and sludges. Center for
Applied Research and Technology, San Antonio, TX.
Levine, P. A. 1975. Sorption of zinc, lead, and cadmium
on a glacial outwash soil. Masters Thesis. University
of Washington, Seattle, WA.
Lichtensein, E. P. 1971. Environmental factors affecting
fate of pesticides. Pp. 190-203 in Degradation of
synthetic organic molecules in the biosphere. National
Academy of Sciences.
Lindsay, W. 1973. Inorganic reactions of sewage wastes
with soils. Pp. 91-96 in Recycling municipal sludges
and effluents on land. National Association of State
Universities and Land Grant Colleges, Washington, D. C.
Little, P- M. 1980. Agents of health significance:
parasites. Pp. 47-59 in G. Bitton, B. L. Damron, G.
T. Edds, and J. M. Davidson, eds., Sludge-health
risks of land application. Ann Arbor Science, Ann
Arbor, MI.
Lucas, J. B., H. R. Pahren, J. A. Ryan, and G. K. Dotson.
1978. The impact of metals present in municipal
sludges upon the human food chain—a risk assessment.
Pp. 132-140 in B. P. Sagik, and C. A. Sorber, eds.,
Risk assessment and health effects of land application
of municipal wastewater and sludges. Center for
Applied Research and Technology, San Antonio, TX.
Luzier, J. E. 1969. Geology and groundwater resources
of southwestern King County, Washington. Water Supply
Bulletin No. 28. U. S. Geological Survey. 260 pp.
Sittig,-Marshall, ed. 1980. Priority toxic pollutants,
health impacts and allowable limits. Noyes Data
Corp., Park Ridge, NJ.
179
-------
Mayer, K. P. 1980. Decomposition of dewatered sewage
sludge applied to a forest soil. Masters Thesis.
University of Washington, Seattle, WA.
McFarland, C. R., G. B. McLucas, J. R. Rigby, and K. L.
Stoffel. 1980. Directory of Washington mining opera-
tions. Information Circular 69. Washington Department
of Natural Resources, Olympia, WA. 100 pp.
McLaren, R. G., and D. V. Crawford. 1973. Studies on
soil copper: the specific adsorption of copper by
soils. Journal Soil Science 24:443-452.
Menzie, C. M. 1972. Fate of pesticides in the environ-
ment. Annual Review of Entomology 17:199-227.
Miller, R. H. 1973. The soil as a biological filter.
Pp. 71-94 in W. E. Sopper, and L. T. Kardos, eds.,
Recycling treated municipal wastewater and sludge
through forest and cropland. Pennsylvania State Univ.
Press, University Park, PA.
Moza, P. N., I. Scheunert, and W. Klein. 1979. Long-
term uptake of lower chlorinated biphenyls and their
conversion products by Spruce trees (Picea abies) from
soil treated with sewage sludge. Chemosphere 8:373-375.
Mullmann, B., and W. Litsky. 1951. Survival of selected
enteric organisms in various types of soil. American
Journal Public Health 41:38-44.
Municipality of Metropolitan Seattle. 1979a. Technical
memorandum no. 1 and appendix: Existing wastewater
facilities and characteristics: wastewater management
study, Lake Washington/Green River basins.
. 1979b. H. P. D. E. S. special study of heavy
metal loads in Renton and West Point treatment plants—
quantities, sources and means of control. 95 pp. +
appendices.
. 1930a. Draft wastewater management plan for
the Lake Washington/Green River basins.
. 1980b. Cost-effectiveness analysis of sys-
temwide sludge management alternatives. 108 pp.
. 1982a. Hydrology report for Pilchuck tree
farm sludge application site. CH2M Hill.
. 1982b. Letter to Washington Department of
Ecology, December 20, 1982.
180
-------
1982c. Preliminary draft Pilchuck tree
farm demonstration sludge application project report.
1983a. Draft long-range sludge management
plan.
1983b. Sludge disposal and reuse cost-
effectiveness evaluation.
. 1983c. Sludge intensive monitoring report.
1983d. Public health risk assessment of
land applying sludge.
. 1983e. Addendum No. 1 to Preliminary Draft
Pilchuck tree farm demonstration application project
report.
. 1983f. Draft Pilchuck tree farm demonstra-
tion sludge application project. 140 pp.
. 1983g. Sludge management plan.
. n.d. Composting of municipal sewage sludge.
Naylor, L. M., and R. C. Loehr. 1981. Increase in
dietary cadmium as a result of application of sewage
sludge to agricultural land. Environmental Science
and Technology 15 (8):881-886.
Naylor, L. M. and R. C. Loehr. 1982. Priority pollutants
in municipal sewage sludge applied to land — Part 1.
Biocycle 23 (4) : 18-22.
Pahren, H. R., J. B. Lucas, J. A. Ryan, and G. K. Dotson.
1979. Health risks associated with land application
of municipal sludge. Journal Water Pollution Control
Federation 51(11):2588-2601.
Parker, G. R., W. W. McFee, and J. M. Kelly- 1978.
Metal distribution in forested ecosystems in urban
and rural northwestern Indiana. Journal of Environ-
mental Quality 7:337-342.
Peter, A., Jr. 1981. Sludge regulations: EPA's new
comprehensive approach. Pp. 1-7 in C. S. Bledsoe, eds.,
Municipal sludge application to Pacific Northwest for-
est lands. College of Forest Resources, University of
Washington, Seattle, WA.
181
-------
Prestwod, Annie K. 1980. Disease transmission by wild
animals from sludge amended land. Pp. 201-212'in
G. Bitton, B. L. Damron, G. T. Edds, and J. M. David-
son, eds., Sludge-health risks of land application.
Ann Arbor Science, Ann Arbor, MI.
Puget Sound Air Pollution Control Agency. 1981. 1981
air quality data summary.
Puget Sound Council of Governments. 1979. Snohomish
subregional development plan. Puget Sound Council of
Governments, Seattle, WA.
Riekerk, H. 1978. The behavior of nutrient elements
added to a forest soil with sewage sludge. Soil
Science Society of America 42:810-816.
Riekerk, H., and R. J. Zasoski. 1979. Effects of de-
watered sludge applications to a Douglas-fir forest
on the soil, leachate, and groundwater composi-
tion. Pp. 35-45 ill 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.
Sagik, Bernard P., Barbara E. Moore, and Charles A.
Sorber. 1979. Public health aspects related to the
land application of municipal sewage effluents and
sludges. Pp. 241-263 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.
Sagik, Bernard P-, S. Monroe Duboise, and Charles A.
Sorber. 1980. Health risks associated with microbial
agents in municipal sludge. Pp. 15-46 in G. Bitton,
B. L. Damron, G. T. Edds, and J. M. DavIcTson, eds.,
Sludge-health risks of land application. Ann Arbor
Science, Ann Arbor, MI.
Sidle, R. C., and L. T. Kardos. 1977. Transport of
heavy metals in a sludge-treated forested area.
Journal of Environmental Quality 6(4):431-437.
Slack, J. M., and Irvin S. Snyder. 1978. Bacteria and
human disease. Yearbook Medical Publishers, Inc.,
Chicago, IL.
Sludge Project Advisory Committee. 1982. Meeting
minutes.
182
-------
Snohoraish County Planning Department. 1974. Snohomish
County shoreline management master program. Snohomish
County, Everett, WA.
. 1975. Arlington area plan, a portion of
the Snohomish County comprehensive plan. Snohomish
County, Everett, WA.
. n.d. Title 18, Snohomish County zoning
ordinance. Snohomish County, Everett, WA.
Soil Conservation Service. 1937. Soil survey Snohomish
County- U. S. Department of Agriculture.
1973. Soil survey - King County area.
U. S. Department of. Agriculture. 100 pp.
Sopper, W. E., and S. N. Kerr. 1979. Renovation of
municipal wastewater in eastern forest ecosystems.
Pp. 61-76 in W. E. Sopper, and S. N. Kerr, eds., Uti-
lization of municipal sewage effluent and sludge on
forest and disturbed land. Pennsylvania State Univ.
Press, University Park, PA.
Trappe, J. M., and W. B. Bollen. 1979. Forest soils
biology. Pp. 145-157 in P- E. Keilman, H. W. Anderson,
D. M. Baumgartner, eds., Forest soils of the Douglas-
fir region. Washington State Univ. Coop Extension
Service, Pullman, WA.
Turnberg, W. L. 1980. Impact of Renton Treatment Plant
effluent upon the Green-Duwamish River. MS/PhD thesis,
School of Public Heatlh, University of Washington.
Ugolini, F. C., H. Dawson, and J. Zachara. 1977. Direct
evidence of particle migration in the soil solution of
a podzol.. Science 198:603-605.
U. S. Department of Agriculture. 1978. The principal
laws relating to forest service activities. Agricul-
tural Handbook No. 453. 359 pp.
U. S. Department of Health, Education and Welfare. 1978a.
Special occupational hazard review for Aldrin/Dieldrin.
Rockville, MD.
1978b. Bioassays of Aldrin and Dieldrin
for possible carcinogenicity. Bethesda, MD.
• 1978c. Bioassay of Methoxychlor for possible
carcinogenicity. Bethesda, MD.
183
-------
. 1979. Bioassay of Endrin for possible car-
cinogenicity. Bethesda, MD.
U. S. Environmental Protection Agency. 1976a. Applica-
tion of sewage sludge to cropland: appraisal to
potential hazards of the heavy metals to plants and
animals. EPA 430/9-76-013. Washington, DC. 63 pp.
. 1976b. Quality criteria for water. EPA
1977/0-222-904. Washington, DC.
. 1977. Municipal sludge management: envi-
ronmental factors. EPA 430/9-77-004. 30 pp. + app.
. 1978a. Sludge treatment and disposal. EPA
625/4-78-012. 2 volumes.
. 1979a. Process design manual - Sludge
treatment and disposal. EPA 625/1-79-011.
. 1979b. Final environmental impact state-
ment - Sewage sludge disposal for the city of Portland,
Oregon. 314 pp.
. 1979c. Criteria for classification of solid
waste disposal facilities and practices. 40 CFR 257:
139-143.
. 1980a. Draft environmental impact state-
ment - Wastewater management plan for the Lake Wash-
ington/Green River basins. 263 pp. -I- appendices.
. 1980b. Potential health effects from per-
sistent organics in wastewater and sludges used for
land application. EPA 600/1-80-025. Cincinnati, OH.
51 pp.
. 1981a. Final EIS - Wastewater management
plan for the Lake Washington/Green River basins.
_ 1981b. Compilation of air pollutant
emission factors: highway mobile sources. EPA 460/
3-81-005.
. 1981c. Evaluation of the health risks
associated with the treatment and disposal of munici-
pal wastewater and sludge. EPA 600/1-80-030. Cincin-
nati, OH. 227 pp.
U. S. Fish and Wildlife Service. 1981. Pacific coast
ecological inventory - User's guide and information
base. 159 pp.
184
-------
U. S. Geological Survey. 1981. Water resources data
for Washington water year 1980. USGS-WRD-WA-80-1.
Volume 1:291-296.
Van Donsel, D., E. Geldreich, and N. Clarke. 1967.
Seasonal variations in survival of indicator bacteria
in soil and their contribution to stormwater pollution.
Applied Microbiology 15:1362-1370.
Venugopal, B., and T. D. Luckey. 1978. Metal toxicity
in mammals. Plenum Press, New York.
Vogt, K., R. Edmonds, and D. Vogt. 1981. Nitrate
leaching in soils after sludge application. Pp. 59-66
in C. S. Bledsoe, ed., Municipal sludge application to
Pacific Northwest forest lands. College of Forest
Resources, University of Washington, Seattle, WA.
Wade, S. E., C. A. Bache, D. J. Lisk. 1982. Cadmium
accumulation by earthworms inhabiting municipal sludge
amended soil. Bull. Environ. Contain. Toxicol. 28:557-
560.
Washington Board of Natural Resources. 1970. Rules and
regulations relating to protection and restoration of
lands disturbed through surface mining.
Washington Department of Ecology. 1972. Regulations re-
lating to minimum functional standards for solid waste
handling. Chap 173-301 WAG.
1977. Washington State water quality
standards. 32 pp.
. 1978. Water quality assessment report 1978.
57 pp.
1980. Washington State solid waste manage-
ment plan. 142 pp.
1982a. Best Management Practices for use of
municipal sewage sludge. WDOE 82-12. 92 pp. + app.
. 1982b. Municipal and domestic sludge uti-
lization guidelines. WDOE 82-11.
1982c. 1981 annual air monitoring data
summary air program. June 1982.
Washington Irrigation & Development Company (WIDCO).
1982a. Sludge utilization program 1982 operation
plan, Thurston County. (Also for Lewis County.)
185
-------
1982b. Sludge utilization program 1982
operating plan, Lewis County. Solid Waste Permit No.
13(81).
West, S. D., R. J. Zasoski, and R. D. Taber. 1981a.
Sludge and wildlife, a summary of findings. Unpublish-
ed report to Metro, Seattle, WA.
West, S., R. Taber, and D. Anderson. 1981b. Wildlife
in sludge-treated plantations. Pp. 115-122 in C. S.
Bledsoe, ed., Municipal sludge application to Pacific
Northwest forest land. College of Forest Resources,
University of Washington, Seattle, WA.
Wiklander, L. 1975. The influence of anions on adsorp-
tion and leaching of cations in soils. Grundforbattring
27 (4) :125-135.
Yeager, J. G. 1980- Risk to animal health from patho-
gens in municipal sludge. Pp. 173-199 in G. Bitton,
B. L. Damron, G. T. Edds, and J. M. Davidson, eds.,
Sludge-health risks of land application. Ann Arbor
Science, Ann Arbor, MI.
Williams, D. E., J. Vlamis, A. H. Pukite, and J. E.
Corey. 1980. Trace element accumulation, movement,
and distribution in the soil profile from massive
application of sewage sludge. Soil Science 129(2):
119-132.
Zasoski, R. L., S. G. Archie, W. C. Swain, and J. D.
Stednick. 1977. The impacts of sewage sludge on
Douglas-fir stands near Port Gamble, Washington.
College of Forest Resources, University of Washington,
Seattle, WA. 42 pp.
Personal Communications
Barkman, J. July, 1982. Aberdeen Treatment Plant.
Batterby, C. July, 1982. Hoquiam Public Works.
Briggs, D. November, 1982. Professor, University of
Washington.
Cochran, J. October, 1982. Environmental Planner,
Municipality of Metropolitan Seattle.
Cost, Tim. November, 1982. Associate Planner,
Snohomish County Planning Department.
186
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Everson, Brad. March, 1983. Washington Department of
Ecology.
Frandsen, L. December, 1982. Pesticide Program Manager,
U. S. Environmental Protection Agency.
Gabrielson, G. July 11, 1983. Manager, West Division,
Water Pollution Control Department, Municipality of
Metropolitan Seattle.
Gschwind, J. January, 1983. Greater Chicago Metro-
politan Sanitation District.
Hammond, D. December, 1982. Project Manager, Renton
Treatment Design, Municipality of Metropolitan Seattle.
Henry, C. November, 1982. University of Washington.
Hickey, R. April, 1982. WIDCO.
Hilderbrand, D. March, 1982. Supervisor, Industrial
Waste Unit, Municipality of Metropolitan Seattle.
Hyde, B. July, 1982. Chahlis Public Works.
Hynes, S. July, 1982. Shelton Treatment Plan.
Keeley, J. August, 1981. U. S. Environmental Protection
Agency, Region 10.
Kolby, T. March, 1982. City of Olympia.
Kopan. April, 1982. City of Edmonds.
Layman, A. July, 1982. Centralia Treatment Plant.
Leney, L. November, 1982. Professor, University of
Washington.
McCarthy, M. July, 1982. Shelton City Hall.
Machno, P. March 1982. Municipality of Metropolitan
Seattle.
Moss, M. July, 1982 and January, 1983. President,
GroCo.
Munger, S. March 1983. Municipality of Metropolitan
Seattle
187
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Newman, G. November, 1982. Senior Planner, Snohomish
County Planning Department.
Olivers, C. April, 1982. City of Everett.
Price, M. March, 1982. City of Tacoma.
Proctor, D. April, 1982. City of Bremerton.
Rice, E. November, 1982. Community Relations, Pilchuck
Tree Farm.
Riley, J. February, 1983. Grants Coordinator, Munici-
pality of Metropolitan Seattle.
Schlagel, B. February, 1982. City of Arlington.
Sludge Project Advisory Committee. April 1983.
Staringer, A. November, 1982 and January 1983. Assis-
tant Forester, Pilchuck Tree Farm.
Sorber, Dr. C. A. March 1983. University of Texas at
San Antonio, Texas.
Thorn, J. July, 1982. Longview Wastewater Treatment
Plant.
Uchida, B. January, 1983. Process Control Supervisor,
Municipality of Metropolitan Seattle.
Willey, A. January, 1983. Environmental Health
Specialist, Environmental Health Division, Snohomish
Health District.
Zasoski, R. December, 1982. Professor, University of
Washington.
188
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Chapter 7
Letters of Comment
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Chapter 7
COMMENTS RECEIVED ON DRAFT EIS AND
RESPONSES TO COMMENTS
Introduction
The public comment period on the Draft EIS lasted from
April 15, 1983 to May 31, 1983. During the review period, EPA
received written comments on the EIS from 4 federal agencies,
6 state agencies, 4 regional or local agencies, and 19 citizens.
Some of these comment letters were addressed to Metro and
duplicated and forwarded to EPA. A petition was also received
with 251 signatures from residents of the Arlington area who are
opposed to the sludge application program on the Pilchuck Tree
Farm.
This chapter presents a summary of the public hearing held
in May 1983, copies of all written comments received by EPA on
the Draft EIS, and responses to each comment. Since each comment
letter incorporates a number of distinct comments, a numbering
system has been added to the margin of each letter indicating the
specific statements being responded to; responses to each of the
statements are then grouped following each letter. Several
issues raised in these letters are specific to the Pilchuck
demonstration project and therefore have been responded to in one
place. Responses to the most frequently received comments are
presented in the FOREWORD to this EIS.
Summary of Public Hearings
Joint EPA and Metro public hearings on EPA's Draft EIS and
Metro's Draft Sludge Management Plan were held on May 17, 1983 in
Seattle and on May 19, 1983 in Arlington, Washington.
Mr. Richard Thiel of EPA and Beth Bland, Chairperson of Metro's
Water Quality Committee, were co-chairpersons for the hearings.
Presentations on the Draft Plan and Draft EIS were made by
Peter Machno and Larry Sasser of Metro, and Jonathan Ives of
Jones & Stokes Associates, Inc.
At the Seattle public hearing, testimony was presented by
members of the Citizens to Save Puget Sound and the Washington
Environmental Council. Comments received at this hearing focused
on the need for greater pretreatment of industrial wastes
entering Metro's waste stream and the need for public involvement
on all future sludge application projects proposed by Metro.
Concerns were also expressed regarding accumulation of toxicants
189
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and their effect on wildlife (silviculture and soil reclamation
options), use of herbicides to control unwanted vegetation on
land where sludge has been applied (soil reclamation option),
adequate public information and labeling (compost option), and
the need for improved pretreatment (agriculture option).
At the Arlington public hearing Mr. Duane Weston, of the
Pilchuck Tree Farm, presented an overview of the involvement of
the Pilchuck Tree Farm with using sludge. Following Metro and
EPA staff presentations, testimony was received from 14 citizens
of the Bryant and Arlington area and from the Pilchuck Advisory
Committee (Appendix I). Primary concerns expressed were the need
for improved pretreatment of industrial wastes; the lack of
control over access to the site by domestic animals and children;
effect on wildlife; effect on property values; health risk;
unknowns regarding long-term effects; impact on berries and
mushrooms; nitrates; trucking; method and rationale for site
selection; and lack of standards for organic or chemical
contamination in groundwater.
During a question-and-answer session, citizens requested
information on width of buffer zones, compensation for pollution
of water resources, application procedures to account for weath-
er, incineration of sludge rather than land application, water
quality testing procedures, and sludge hauling.
Responses to the most frequently raised concerns at the
public hearings are presented in the FOREWORD to this Final EIS.
190
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FEDERAL AGENCIES
191
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192
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United Stales Department of the Interior
OFFICE OF THE SECRETARY
PACIFIC NORTHWEST REGION
500 N.E. Mullnonuh Street, Suite 1692, Portland, Oregon 97232
May 24, 1983
ER 83/472
Kathryn Davidson
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
The Department of the Interior has reviewed the draft environmental state-
ment for Sludge Management Plan, Municipality of Metropolitan Seattle,
Washington and offer the following comments.
General Comments
Fish and Uildlife Resources
The Fish and Uildlife Service (FWS) advises that if the project eventually
requires permits from the U.S. Coast Guard or the U.S. Army Corps of Engi-
neers, they may provide additional and separate evaluation. In that evalu-
ation, they may concur, make stipulations, or object to proposed construc-
tion practices which could cause impacts to fish and wildlife resources.
If such permits do become necessary, the FUS encourages the project sponsor
to contact them at (206) 753-9440 before making application. The FUS may
be able to give guidance on design criteria which will speed the permit
review process.
Recreational Resources
The National Park Service (NPS) reports that sludge management at the West
Point Treatment Plant has a direct impact on the City of Seattle's adjacent
Discovery Park, a former Federal surplus property acquired by the City for
public park purposes. However, the draft environmental statement ignores
this basic land use relationship.
In 1972, Dan Kiley and Partners prepared the Fort Lawton Park Plan. In
that plan, Mr. Kiley proposed the earliest possible removal of the present
sludge lagoons. He stated, "Service traffic to and from the plant could
be a real distraction and real 'pollution' if generated through the park or
across the beaches". The plan was slightly modified in 1974 to provide
an access road through the park for Metro vehicles and to more precisely
define the relationship of the West Point Plant to Discovery Park. It
said:
Metro Access
In this planning restudy, it was first proposed that the
Metro vehicular access be via the Park Entrance Road,
along the Mall, thence southerly by the North Bluff picnic
area to the vicinity of the Capehart housing and then down
to West Point. Since such a route was circuitous, having
three significant elevation changes, and traversing almost
the entirety of the projected heavy use area of the park,
another route was sought. Discussions with Metro showed
greater use of trucking to move sludge than had been anti-
cipated. The optimum choice seems to be to designate the
present Metro access road as a restricted service road,
with limited use by public vehicles and mini-bus service,
and used in part also for the Scenic Loop ... It would
appear that this alignment cannot be improved upon. In the
future the possibility of another method of sludge disposal
can be hoped for—by barging or piping, for example.
From a design standpoint and because the shores and beaches
belong to the scene and character of the Park, all Metro
developments should be considered as a part of the Park
environment. No Metro plant development should take place
on the South Shores; the present sludge lagoon should be
removed as soon as possible and any future Metro plant ex-
pansion limited to the north side of the present treatment
plant. The rip-rap edge along the north side should be
available to the public as an important promenade connec-
ting the two proposed Park water access docks and the trail
system leading from them into the hinterland. The South
Beach is broad and spacious at low tide. It's great ex-
panse, backed by high bluffs, together with its isolation,
dramatize its grandeur and its mystery. The beaches need
to be open for public walking along the entire outside of
the peninsula.
EPA's Sludge Management Plan Preferred Program will expand the sludge
lagoons at West Point and double the number of trucks hauling sludge by
the year 2000. The processing of sludge, now done exclusively at the
West Point Plant, will be incorporated into the Rentqn treatment plant.
The percent of the total sludge treatment to be handled by each plant
is not stated. Further development of the processing capability of the
Renton plant as quickly as possible to minimize the processing required
at the West Point Plant should be considered as an alternative and/or
mitigating measure to reduce the hauling of sludge through the park and
the expansion of lagoons. Removal of sludge by barge or some means other
than truck traffic through the park is another alternative.
MAY 26 1983
ENVIRONMENT*! r'.'.LUA1ION
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Hater Resources
The U.S. Geological Survey (GS) reports that It Is not clear whether moni-
toring will Include measurements of ground-water levels In and adjacent to
areas of sludge application. Because the liquid content of the sludge will
apparently amount to 80 percent or nore of the sludge applied (e.g. p. 54,
57), the statement should address the potential for ground-water Bounding
beneath areas of application. As described, the upper, relatively permeable
materials of the sites would be underlain by dense glacial till, which would
have low permeability (p. 87, 106, 125). Thus, the possibility for local
mounding of water levels should be assessed in evaluating the potential for
downgradient migration of contaninants toward surrounding private wells.
It is stated that the likelihood of significant impacts on ground and sur-
face water draining the composting sites would be eliminated by complete
paving of the sites and development of a runoff collection system (p. 38,
par. 7). Because of the possibility of structural failure of the paved
surface and runoff collection systea, the chemical and nicrobial quality
of the runoff should be analyzed and, if necessary, the water should be
treated.
Office of UivlronnicnUI Project Review
Director. fl$h «,KJ Wildlife
Regional Director, fWS
Regional Director, NPS
Director. Geological Survey
Thank you for the opportunity to review and coanent on this draft
environmental statement.
Sincerely,
Charles S. PolityU
Regional Environmental Officer
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vo
01
Response to Department of the Interior Letter of May 24, 1983
1. Comment noted.
2. Table 3-2 of the EIS depicts the projected truck traffic
from the West Point treatment plants through the year 2000.
The number of trucks leaving the facility on a daily basis
will remain at nine trucks (existing traffic) through 1985,
and once the Renton treatment plant expansion is completed
in 1988, the number of trucks per day leaving West Point
will decrease to 1980 traffic volumes through the year 2000.
Therefore, there would not be any significant impact on the
Discovery Park area.
Metro has no plans to construct a sludge lagoon at West
Point. The old sludge storage lagoon was dismantled in 1980
and 1981 and is now used as a beach. The new sludge storage
basins would be constructed at the Pilchuck Tree Farm and
other sludge application sites as needed.
3. Completion of the Renton expansion and sludge treatment
facilities is scheduled for 1987. Sludge from Alki, Carkeek
Park, Richmond Beach, and West Point will continue to be
treated at West Point. The percent of the total sludge
volume that will be handled by each plant is not precisely
known and will depend on future treatment procedures (such
as the addition of alum at West Point); however, it is
anticipated that the approximate 1990 sludge distribution
between the two plants will be 43 percent for Renton and 57
percent for West Point. By the year 2000, the distribution
will be approximately 50/50.
4. Barge removal of sludge from both West Point and Renton was
investigated by Metro as part of an earlier site-specific
study. Barge removal would require acquisition of loading
facilities, barges, and unloading facilities requiring
considerable capital expenditure. Lack of available land
and local resident objections also dismissed further
consideration of this alternative. Unloading sites have not
been investigated and, in most cases, transportation by
truck would still be required to the ultimate land
application sites.
5. Groundwater quality monitoring wells will also be used to
determine groundwater flow and direction. This will include
monitoring of water table elevations.
6. It is extremely unlikely that application of 1 inch of
sludge will result in a significant mounding in the water
table. At 80 percent liquids, 1 inch of sludge would
contribute 0.8 inch of liquid. This volume of liquid would
raise the water table by 4 inches in soils with a porosity
equal to 0.2, assuming no evaporation, plant uptake, or
adsorption were to occur and the total volume was
transmitted to the saturated zone.
7. Proper design and maintenance of the runoff collection
system and connection to the local sewer system should
remove the need for on-site treatment. Annual inspections,
required for permit renewal, would ensure proper operations.
-------
United States Department of the Interior
1792 (13O.1)
BUREAU OF LAND MANAGEMENT
Spokane District Office
East 4217 Main Avenue
Spokane. Washington 99202
Response to BLM Letter of June 9, 1983
1. No response required.
June 9, 1983
«£>
Kathryn Davidson
Environmental Evaluation Branch H/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle. WA 98101
Dear Ms. Davidson:
We have reviewed your EIS concerning the Municipality of Metropolitan Seattle
Sludge Management Flan, and as a result of this review we have no comments.
Thank you for the opportunity to review this docuaent.
Sincerely yours.
Gary J. Yeager
Environmental Coordinator
-------
DEPARTMENT OF HEALTH 4 HUMAN SERVICES
Public Health Service
Centers for Disease Control
Atlanta GA 30333
(404) 452-4257
Hay 23, 1983
Response to DHHS Letter of May 23, 1983
1. No response required.
VQ
Ms. Kathryn Davidson
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Davidson:
We have reviewed the Draft Environmental Impact Statement (EIS) for the Muni-
cipality of Metropolitan Seattle Sludge Management Plan. We are responding
on behalf of the Public Health Service.
We have reviewed this document for possible health effects and have no comments
to offer since we believe the proposed alternatives have been adequately
addressed.
Thank you for the opportunity to review this Draft EtS. Please send us a copy
of the final document when it becomes available.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
XRY 39 1963
ENVIRONMENTAL EVALUATION
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DEPARTMENT OF THE ARMY
SEATTLE DISTRICT. CORPS or ENGINEERS
PO BOX C J733
I HAY
Response to ACOE Letter of May 3, 1983
1. No response required.
Planning Branch
00
Kathryn Davidson
Environmental Evaluation Branch H/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ha. Davidson:
We have reviewed the draft environmental inpact statement
on the proposed Municipality of Metropolitan Seattle (Metro)
Sludge Management Plan with respect to the U.S. Amy Corps of
Engineers' areas of respoosibility for flood control, navigation,
and regulatory functions. We have no comments.
Thank you for the opportunity to review this statement.
Sincerely,
r~
Mj
W
Scllcvold, P.E.
Chief, Engineering Division
S 1963
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STATE AGENCIES
199
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200
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MIN SUIIMVN
Governor
IACOB
Dire* lor
si Mr oi vx -\siiiNGroN
OrflCE OF ARCHAEOlOf.Y AND HISTORIC PRESERVATION
III IV<>>( lu.'iin I«>| Ui
-------
(XMA1O W MOOS
0-Klor
K»IM SdllMAN
Govctnof
!>TAH <»
DEPARTMENT OF ECOLOGY
AW Vup PI II . Ofinpu ttjifeflun *SlM • (.1*M5»«OUO
SIATf Of WASmGTON
DEPARTMENT Of ECOLOGY
Mjrf Stop
• (Ml ^i'H>tXa
Hay 31. 1963
O
tsj
Kathryn Davidson
Environmental Protection Agency
Environmental Evaluation Branch
MS - 443, 1200 6th Avenue
Seattle, HA 98101
Ms. Davidson:
Me have coordinated the review of the draft environmental
impact statement for METRO'S Sludge Management Plan with
other state agencies. The only agencies responding are
The Office of Archaeology, Historic Preservation, and State
Parks and Recreation Ctnmission. Their letters, along with
Garments from this department, are attached.
If you have any questions, please contact the appropriate
agency, or Mr. David Wright of our Northwest Reoional Office
at (206) 885-1900.
Sincerely,
Dennis L. Lundbiad, Supervisor
Operations Management Division
Office of Field Operations
DLL:pp
cc: Agencies
JUN 1 1983
,
'L. IICM
Specific Comments
On The METRO SLUDGE
Plan Draft EIS
page 9 Table S-3 Impacts of the PiIchock Demonstration Project. The mitigative
measure for runoff from the site into surface water is to cease sludge
application if the ground is frozen. This does not address the probable
case of high precipitation caused site runoff and an appropriate mitigative
response.
page 11 Table S-4 - In the List of Possible Permits and Approvals Required by
METRO, the Departnent of Geology will have to issue a report of findings
for the Land Application of Sludge Permit isgjprt by the Snohomish
Health District in accordance with Chapter 70.95.180 FCM.
page 120 (Jhder assessment of iiqpacts METRO is proposing raininvm 100 foot buffer
zones plus a 25 foot setback on bluffs. The State Best Management
Practices reootraend a nininm 200 foot buffer zone. The steep canyon
walls in Kunze and Rock Creek could account for the difference, but
they should clarify this.
129 On page 127 the EIS states that the Host likely inpact of the proposed
project will be associated with the movement of nitrate from the sludge
into the underlying groundwaters, but on page 127 the draft EIS indi-
cates background levels of nitrate directly beneath the site have not
been measured. One of the main purposes of this dencnstration project
is to provide information to demonstrate the beneficial use of sludge
without adverse effects on public health or environmental quality
groundwater monitoring wells are in place on the proposed dencnstra-
tion site; it is essential the background baseline monitoring be
accomplished prior to any sludge application.
page 130 The draft EIS indicates that the METRO monitoring response plan would
include action in the event any wells reached one half of the maxuiun
contaminant levels in drinking water allowed by EPA (40CFR257).
The Drinking Mater Protection Plan outlined in the Draft Plan - Pilchuck
Tree Farm Demonstration Sludge Application project dees not initiate
a response until contaminant levels er™**) Federal and State Primary
Drinking Hater Standards. This discrepancy needs to be resolved.
page 166 To minimize aerosol exposure to sludge at the Pilchuck Site, the draft
EIS indicates mitigating measures would consist of:
1. Buffer zones
2. Application during daylight hours of high solar radiation
and low humidity.
3. Limiting spraying during high wind conditions.
Earlier in the document the indication is that study spraying will occur
CD
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Page 2
Response to WDOE Letter of May 31, 1983
between October 15 and March 15. It is doubtful low humidity conditions
will exist. The specific conditions to be in the sludge operation plan
governing application should be included to help assess the proposed
raitigative measures.
page 217- The nitrogen loadings, conversions, uptake and leaching identified on
219 these three pages is not consistent with the loading depicted in the
detailed Draft Plan - Pilchuck Tree Farm Demonstration Sludge Application
Project in Tables 7-2 and 7-3. These should be resolved to assess the
potential for nitrate migration at the demonstration site. As indicated
earlier in the draft EIS, this is the most likely impact.
N)
O
U)
1. Metro has indicated that sludge would not be applied during
periods of high rainfall. Runoff of sludge off-site is not
likely to constitute a problem because of: 1) the gentle
slope of the site, 2) the porous soil, and 3) the results of
studies conducted at Pack Forest indicate that sludge does
not readily move, even on steep slopes.
2. That requirement has been added to the summary table.
3. Metro has proposed a 200-foot wide buffer from application
sites to streams. The reference to 100 feet on page 120 of
the Draft EIS was incorrect. The appropriate change was
made in the Final EIS.
4. Metro has monitored baseline nitrate conditions at the
proposed sites; however, data were not available at the time
of publication of the Draft EIS. Sampling has been conduct-
ed at nearby neighborhood wells and at lysimeters. Metro
plans to sample at lysimeters once per month for nitrite,
nitrate, ammonia, orthophosphate, and pH to establish base-
line conditions. After sludge is applied, sampling frequen-
cy will be increased to two times per month.
5. The monitoring and response procedure outline by Metro in
the Draft Pilchuck Tree Farm project (pages 65 through 68)
now focuses on direction of flow of groundwater relative to
domestic wells located north of the site. In both Condi-
tion 1 and Condition 3, Metro would provide action by col-
lecting and analyzing samples. If groundwater is found to
flow from the site toward domestic wells (south to north) ,
under Condition 1, Metro would evaluate the potential for
contamination and, if necessary, provide an alternative
source of drinking water. Under Condition 3, if a domestic
well is found to contain a parameter of concern in excess of
drinking water standards or in excess of baseline data (if
the standards were exceeded during baseline monitoring),
Metro would determine the direction of groundwater flow and
investigate the cause. At monitoring wells, springs, or
streams located downgradient of the application sites
(Conditions 2 and 4), Metro would investigate the cause and
report findings if any parameter exceeds the drinking water
standards.
6. It is recognized that fall and winter months in Arlington
are not times of high solar radiation or low humidity.
Based on studies conducted by Harding et al. (EPA 1980) ,
aerosol transport is least likely to occur during times of
low humidity and high solar radiation. Additionally, Dorcey
and Howe (in Sagik and Sorber 1977), indicated that aerosols
can be reduced by avoiding application during high winds and
at night. Metro should establish weather conditions under
which sludge would not be applied (e.g., at night, during
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ro
o
heavy rains, high winds, etc.), as a part of the sludge
operation plan.
7. The projection of nitrate leaching of up to 75 pounds during
the first year of sludge application was based on the most
recent studies conducted by Henry and Cole (1983) at Pack
Forest and from conversations with Dr. Henry concerning the
fate of nitrogen in a forested environment. Metro's
estimates of nitrate leaching to groundwater during the
first year were derived by choosing a variety of values from
a number of information sources (Table 7-2 of the Draft
Pilchuck Plan). On pages 55 and 56 of Metro's Pilchuck
Plan, an explanation is given as to why nitrate leaching may
be less than 75 pounds during the first year. We feel that
the first year estimate of nitrate leaching presented in the
EIS represents the quantity which can reasonably be expected
for an established plantation. Even if all 75 pounds are
leached, the resultant nitrate value in the groundwater
would be less than the drinking water standard of 10 rag/1 of
nitrates.
Cxmrrnor
STATE Of WASHMCTON
DEPARTMENT OF GAME
Wahnglcn HBKW • IM>)7fl-i7(JO
May 31, 1983
uc
Kathryn Davidson
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle. Washington 98101
DRAFT ENVIRONMENTAL IMPACT STATEMENT:
Municipality of Metropolitan Seattle
Sludge Management Plan
Dear Ms. Davidson:
Your document has been reviewed by our staff as requested; our comments follow.
We are concerned over the scope of this document as 1t relates to Metro's
Draft Sludge Management Plan. Although this DEIS purports to cover all aspects
of Metro's plan, this DEIS does not address the full-scale impacts of the plan.
Several of the plan's preferred alternatives Involve land application of sludge.
A considerable acreage of land would be required for land application of lOOt
of Metro's projected sludge production from 1990 to 2000. As stated 1n the
plan, the amount could total 11,000 acres for agricultural application or up
to 41,000 acres for sllvlcultural application. However, this DEIS does not
discuss the impacts of such large-scale land use on fish, wildlife, habitat,
and related recreation.
Agricultural lands provide valuable habitat for many types of wildlife. Including
waterfowl, hawks, songbirds, upland game birds, and small mammals. Adjacent
streams could be used by both anadromous and resident fish. Sludge application
would Impact adjacent habitats such as streams, wetlands, and fencerows, as well
as the farm land habitat Itself. These impacts are not mentioned in the document.
The DEIS does not discuss Impacts from sllvlcultural application on a regional
basis. Although Impacts from a localized application of sludge (the Pilchuck
Tree Farm Demonstration Project) are adequately described, the impacts of Metro's
total program of sllvlcultural application on fish, wildlife, habitat, and
related recreation are not addressed. The cumulative Impacts would be significant
(f up to 41,000 acres of forest land were treated with sludge.
In summary, this DEIS largely focuses on site-specific Impacts of the proposed
Pilchuck Tree Farm Project. The Draft Sludge Management Plan also Includes a
five-year plan (1984-1988) which will require additional site selection for
areas of land application and a long-term plan (1990-2000) to use a large
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NJ
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Ul
Kathryn Davidson
May 31, 1983
Page Two
amount of land for agricultural and Silvicultural application. What future
environmental assessment and opportunities for public review will be provided
on these aspects of Metro's plan?
Specific comments on the DEIS follow.
Page 8. Terrestrial Wildlife and Aquatic Life. Table S-3 does not address
cumulative impacts of large-scale land appliedti on.
Page 9, Wildlife. Wildlife will also be Impacted 1f changes In the habitat
result In changes 1n the species composition of the wildlife community. Some
evidence of such changes has been shown on the Pack Forest study site
(West et al., 1981, College of Forest Resources, University of Washington).
Page 64, Five-Year Plan. It appears more appropriate to the Intent of NEPA/SEPA
"to discuss Metro's "five-year plan 1n a draft EIS to allow public review and
comment.
Pages 76-82, Agricultural Application. As mentioned above. Impacts to fish,
wildTife, habTtat, and related recreation are not addressed.
Pages 89-94, Silvicultural Application. Assessment of Impacts. As mentioned
above/cumulative impacts to fish, wildlife, habitat, and related recreation
are not addressed.
Page 94, Silvicultural Application, Mitigation Measures. We support the concept
of buffer zones along streams "and around wetlands and other sensitive areas.
We recommend a minimum width of 200 feet.
Page 120. Surface Water, Assessment of Impacts. According to page 6-8 of Metro's
Draft Sludge Management Plan, the three streams will be protected by minimum
200-foot buffer zones. This document describes 100-foot buffer zones. Which
buffer strip width 1s correct? We support a minimum width of 200 feet.
Thank you for sending your document. We hope you find our comments helpful.
Sincerely,
THE DEPARTMENT OF GAME
Response to WDOG Letter of May 31, 1983
1. The EIS clearly contains a "generic" analysis of impacts
associated with the various alternatives. The plan and EIS
only evaluate the concepts and not the site-specific
analyses; more detailed impact studies will be required when
each site is selected for use.
2. In the final sludge management plan, Metro has dropped the
use of sludge for agricultural application as a preferred
alternative.
3. A discussion of cumulative impacts has been added to the
Final EIS. It is important to note that not all
41,000 acres would receive sludge at the same time, and that
applications would be staggered.
4. For each site selected for sludge application, Metro would
follow SEPA requirements for checklists and EISs, as needed.
5. A discussion of cumulative impacts has been added to the
Final EIS.
6. Comment noted. A discussion regarding impact on wildlife
has been added to the Final EIS.
7. Comment noted. As previously mentioned, Metro will be
required to carry out environmental review for all proposed
future sludge application projects.
8. See response to comment number 2.
9. See response to comment numbers 3 and 5.
10. Comment noted.
11. Buffer zones of 200 feet are being proposed by Metro. See
response to comment number 3 of the WDOE letter.
BW:cv
cc: Agencies
Region
Betsy Wolln, Applied Ecologist
Environmental Affairs Program
Habitat Management Division
-------
(KAMk UX-KAKD
blMl n'\
7) long-term bioaccumulation and sublethal effects of heavy metalvU
in the terrestrial ecosystem; 4$ 2 190)
ENVIRONMENTAL EVALUATION
BRANCH
8) Impacts of restricted access on fish and wildlife oriented
recreation.
We commend Metro's proposed monitoring studies on the Pllchuck Tree Farm
Demonstration Project. We also support the 200-foot minimum buffer zone along
Kunze Creek, Rock Creek, and the North Fork Stillaguamish River. We recommend
several additions to the proposed monitoring program:
1) Studies of the aquatic ecosystem should Include monitoring
bioaccumulation in fish and investigating its sublethal
impacts, as well as monitoring water quality and fish popula-
tions.
2) Studies of habitat use by terrestrial wildlife on the Pack
Forest site included only black-tailed deer and small mammals.
The studies should be expanded to monitor changes in bird
species numbers and diversity. Upland game birds, waterfowl,
and songbirds may be affected by sludge application to farm
lands and forests. Reptiles and amphibians should also be
studied.
3) Studies of bioaccumulation in terrestrial wildlife should also
be expanded to include the full range of prey species taken by
hawks, owls, and other large predators. Sublethal effects of
heavy metal accumulation need investigation.
Thank you for sending your document. We hope you find these comments helpful.
Sincerely,
THE DEPARTMENT OF GAME
BW:cv
cc: Agencies
Region
Betsy Hoi in. Applied Ecologist
Environmental Affairs Program
Habitat Management Division
-------
Response to WDOG Letter of May 31, 1983
1. No response required.
Department of Natural Resources
South Puget Sound Area
P. 0. Box 68
Enumclaw, Washington 9B022-0068
BRIAN J. BOYLE
Cummi»iuncr ol Publu- Lam
DATE: Aprj] 20, 1983
N)
O
TO: Kathryn Davidson
Environmental Evaluation Branch M/S
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98)01
FROM:
Donald Theoe
Governmental Forester
South Puget Sound Area
SUBJECT: REVIEW OF DRAFT ENVIRONMENTAL IMPACT STATEMENT
ACTION SPONSOR Environmental Protection Agency
PROJECT Municipality of Metropolitan Seattle
Sludge Management Plan.
We do not have an interest in the above project and
have no comments on the proposal.
We do have an interest in the above project and wish
to make the following comments:
cc: DNR SEPA Center
AFR 2 I
fWVWONMENTAL EVALUATION
BKAMCH
Equal Opportunity Employer
-------
Response to WDNR Letter of April 20, 1983
1. No response required.
lOMNSPlllMAN
Governor
lANTVfTIN
Dveclor
STATE Of WAiWMCTON
WASHINGTON STATE PARKS AND RECREATION COMMISSION
7>SOOftm*MerUne.Wl • Otftnpu, Wishnglon 9B5CH « l2Ob)75J-5755
April 19, 1983
TO:
K)
O
CO
FROM:
RE:
Marilyn 0. Monk
METRO
Seattle, WA 98104
Barbara Ritchie. NEPA Coordinator
Department of Ecology
Olympla PV-11
David W. Heiser, E.P.
Chief, Environmental Coordination
Draft EIS - METRO Sludge Management Plan
(35-2650-1820 - E-2528)
The staff of the Washington State Parks and Recreation Commission
has reviewed the above-noted document and finds that it will have
no effect on properties under the management or control of the
C omission.
Thank you for the opportunity to review and comment.
bh
cc: Kathryn Davidson, EPA
-------
Response to Washington State Parks and Recreation Commission
Letter of April 19, 1983~~~
1. No response required.
KNIN SMI I MAN
<~.»>.i;lij/> -iH'illI • (-'!»>( ~* t-mil • (•><
June 10, 1983
METRO
Exchange Building
821 Second Avenue
Seattle, Washington
98104
ro
o
Attention Ms. Marilyn Monk, Sludge Program
Gentlemen:
Draft Environmental Impact Statement and
Draft Management Plan for METRO Sludge
We support a planned program which will guide METRO in sludge management
to ensure proper treatment design, transportation and disposal in relation
to protection of water quality and aquatic resources in Washington State.
The basic guide documents to follow in developing this plan include Guide-
lines and Best Management Practices (BMP's) for Municipal Sludge Management
for Washington State by Washington State Department of Ecology.
The Draft Environmental Impact Statement and Draft Sludge Management Plan
required by METRO appear to be well written and include necessary concerns
and requirements for proper sludge management in relation to environmental
protection.
The products of sludge that are most directly harmful are organic loading
(nitrates) and heavy metals. We emphasize that sludge products must be
controlled on applied land sites and be restricted from entering ground
and surface waters. Assurance of this protection in land application is
dependent upon the sludge management planning process, including but not
restricted to, careful consideration of soils, slopes, and drainages in
site selection; proper application rates to prevent migration from the site;
adequate buffer zones along drainages; and nonitoring to ensure control.
Surface waters that flow from a sludge-treated area should be sampled above
and below the point it mixes with receiving streams. Ground, water should be
monitored from well both up-gradient and down-gradient from the sludge
-------
METRO
- 2 -
June 10, 1983
to
(->
o
treated areas. If sampling shows trends and/or readings which Indicate
polluting potential, plans for control should start.
We support the development of wastewater treatment plants intended to
reduce the concentration of heavy metals by location.
If you have any questions, please contact me at (206) 753-2983.
Sincerely,
Jim Fraser, Regional Habitat Manager
Habitat Management Division
JF:mr
cc: Game
SEPA File
Response to Washington Department of Fisheries Letter of June 10,
19 83
1. Comment noted.
2. These factors were considered in Metro's design of the water
quality monitoring program.
-------
LOCAL AGENCIES
211
-------
212
-------
SNOHOMISH
HEALTH
DISTRICT
Courthouse
Everett. Washington 98201
\iea Code 206 259-9440
CLARIS HYATT. MO . MPH
DISTRICT MEMBERS
COUNTV
U)
:iTIES AND TOWNS
Arlmjlon
May 10, 1983
Ms. KaChryn Davidson
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Re: Draft E.I.S. - Municipality of Metropolitan Seattle
Sludge Management Plan
Dear Ms. Davidson:
The Snohomish Health District staff has reviewed the
above referenced documents as well as METRO'S April 1983
Draft Sludge Management Plan. The following comprises
our comments regarding these documents.
It is obvious that municipal sewage sludge utilization
and disposal will be an increasingly difficult problem
to resolve. This is true for most municipalities, not
just Seattle. Traditional methods of disposal need to
be scrutinized for their effects on health and the
environment. Mew methods will have to be researched
and evaluated.
These documents discuss METRO'S proposed Pilchuck Tree
Farm Demonstration Project. The project is intended to
research the suitability of sludge utilization in tree
farming operations. We want to emphasize that while we
support the concept of research, the health of the
public must be protected. This project would require
a sludge utilization permit. To date, we have not
received an application for this project, nor have we
received operating plans and specifications for this
proposal. Until such time as we have received and
reviewed final plans and specifications for this project,
we cannot make a determination as to the suitability of
this site for the proposed demonstration project. No
permit will be issued until we are assured that adequate
safeguards have been incorporated into the project.
Furthermore, if the permit is issued, ongoing sampling
and inspection will be required to continuously update
our information, and insure continued protection of the
public health and environmental quality.
These documents imply that METRO intends to expand the
Pilchuck Tree Farm site at a future date into a major,
permanent disposal site. We want to clarify our position
that any expansion of the site beyond the demonstration
v, V 1 1
Re: Draft E.I.S. - Municipality of Metropolitan Seattle
Sludge Management Plan
May 10, 1983
Page 2
project would be considered to be a separate project. If we
decide to issue an operating permit for the demonstration
project, we would not be committing ourselves to also approving
an expanded project. Any expanded project would require a
separate determination as to its acceptability and a new permit
would be required.
We appreciate the opportunity to review these documents. If
you have any questions, please contact this office at 259-0693.
Very truly yours,
L . /(• /Jl
C. H. Mangurir R.S., Director
Environmental Health Division
CHM:sei
CC: METRO
Claris Hyatt, M.D. , Health Officer
-------
Response to Snohomish Health District Letter of Hay 10, 1983
1. Metro will be submitting an application for the sludge
utilization permit from the Snohomish Health District. It
is understood that any expansion of sludge application at
Pilchuck beyond that designated in the plan and EIS would be
subject to a separate evaluation process.
rvj
*£2SL
WILLIS 0. TUCKER
County fxeculm
DEPARTMENT OF PUBLIC WORKS
GERALD E. WEED. P.E.. Director
FIFTH FLOOR. COUNTY ADMINISTRATION BUILDING
EVERETT. WASHINGTON U201
I2W1 H»MM • So*. M»»«M • Toll F™ LSOO-SM 43S7
(lay ll/ 1983
Kathryn Davidson
Environmental evaluation Branch H/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Re: DEIS Municipality of f.etropolitan Seattle
Sludge Management Plan
Dear Us. Davidson:
INVWONMENUl CVM.UMKM
BftAMCH
The Solid Waste Division of the Snohoraish County Departuent on Public
Works has reviewed the draft environmental impact statement tot the
proposed METRO Sludge Management Plan and ofterc the following co.,.-
r.iontt, for your consideration:
1. The Department of Public Works is the designated join., v.^jte
management planning ana implementation agency for Snohc. iish
County under Section 400C of the federal Resource Conser viticn
ana Recovery Act (P.CRA). The METRO Pilchuck Tree Far.., .luu.jC-
uisposal program planneu in Snolumisli County sl.cul^ L.^ inclaJcu
in tlic Snohouish County Couprehonsive Sol 10 l.'astc .'.c-nai-i., cnt
Plan prepared and raaintaineo by the Department of Public "orc^.
The Municipality of Metropolitan Seattle should mJvist the
Solid Waste Division of the Snohomish County Dcpor u.icnt of
Public Works of the status of the Pilchuck Tree Pan.) sluuge
disposal protjrara in regular progress reports.
2. The Snohouish County Coiaprcliensi ve Solid Waste i:ana>je:.icnt Plan.
auo[)tcd by the Washington Department of Ecology on liarch ?2»
1903, establishes the Lol lowing policy with respect to slu^ujc
Disposal in Snohomish County:
•It is rocoi.uuendcd that e nooni
require sludge generators to implement
other than codisposal at a sanitary Ijndiill
applicable. II coili^posal io to be .jj-provi *!, it
the Snohoniiuli Health ni.,trict
disposal methods
applicable. II coui^posal 10 to be .jj-provi^<» it i~
recommended that adequate ilcwatcrin to over Co..u- opt-r..-
tional [iroblcms. be required prior to disiosal at a sani-
tary landfill. Hazardous sludges shall not be acceptor."
-------
Kathryn Davidson
L'PA
5/11/83
Page 2
Ul
The proposed Pilchuck Tree Farm Deuonstration Project in Arlington
Washington* is consistent with the sludge disposal policies in the
Snohoi.iish County Comprehensive Solid Waste Management Plan. Future
compliance is contingent upon METRO sludge meeting solid waste clas-
sification according to EPA regulations (40 CFP,/ Parts 260-265) .
Hazardous sludges cannot be applied to agricultural or silvicultural
lands in Snohomish County.
3. Any proposed future expansion of the sludge application sites
and facilities at the Pilchuck Tree Farm should lie outside the
established 100-year floodplain of the Horth Fork of the
Stillaguar.iish River. Chapter 10.68 of the Snohomish County
Coue specifically prohibits solid waste disposal within the
100-year floodplain. Other state and federal regulations also
limit lanafilling and land application activities in designated
flood zone areas.
4. Snohomish County promotes the concept of waste incineration
with 2i.ercjy recovery as a more desirable management program
than the continued landfilling of all municipal solid waste
Materials. METRO might reconsider the coincineration of slucige
with the Municipal solid wastes of Pierce. King or Snohomish
Counties as a long-terra solution to regional solid waste dispo-
sal prooleiiis. METRO'S participation may enhance the feasibil-
ity of a waste-to-energy incineration facility in one or more
of these counties* helping reduce the significant municipal
solid waste landfill impacts in the Puget Sound area.
Thank you for the opportunity to review and comment on the Municipal-
ity of Metropolitan Seattle Sludge Management Plan. If I can provide
additional information or assitance> please telephone me at (SCAiJ)
649-94CB.
Response to Snohomish County Department of Public Works Letter of
May 11, 1983
The request for regular progress reports has been transmit-
ted to Metro staff.
1.
2.
3.
4.
Comment noted.
Comment noted.
In the sludge management plan, Metro indicated Alterna-
tive 4B (coincineration with municipal solid waste) to be an
"alternative deferred for possible future consideration."
This alternative may be considered later in the planning
period.
1UCHAIJL JAMES HUDDLF.STOtl
Environmental Specialist
Solid Haste Division
Avcry i/ellst DOE
Charles lianyum, SHD
-------
SIMOHOMISH COUNTY
OFFICE of COMMUNITY PLANNING
COUNTY ADMINISTRATION BUILDING • EVERETT. WASHINGTON 98201 • (2061 2599311
G.O.J. F. Sh.rwin. Jr.. Diticlot
Hay 27, 1983
Kathryn Davidson
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
RE: Municipality of Metropolitan Seattle Slude Management Plan EIS
Dear Ms. Davidson:
The following are our comments regarding the above EIS:
1. On page 95, it is stated that site monitoring will be done for
five years after application. Some of the hazardous viruses,
bacteria, and toxicants could have effects beyond the five-
year limit. Since present data is not conclusive on this
point, we suggest that monitoring persist until field data
shows that no hazards exist.
2. On page 152, it is unclear how far from the application sites
the odor is likely to be noticeable. Also, there is no
rationale stated for truck traffic continuing through the
night. This seems to be an avoidable impact.
3. The section on wildlife (page 130) does not discuss the
potential for viral infection of animals, nor the possibility
of such animals becoming vectors. Is there any likelihood of
this happening?
4. The mitigating measures listed on page 167 are listed as items
which 'should be considered.* All four of these items are
vital to the safe operation of the project. Site operation
procedures are critical in avoiding impacts on nearby streams
and houses. The procedures should be carefully designed and
strictly enforced.
Thank you for the opportunity to comment on this document.
Sincerely,
DEPARTMENT OP PLANNING AND COMMUNITY DEVELOPMENT
MAY 21 i"J
Response to Snohomish County Office of Community Planning Letter
of May 27, 1983
1. The Final EIS reflects this concern and has been added as a
mitigation measure to the Public Health section of the
Pilchuck Impact Analysis, rather than appear in the
"generic" discussion of silvicultural application.
2. The actual distance that odor from sprayed sludge is
detectable on the Pilchuck site has not been estimated.
Several factors such as wind direction and velocity, other
weather conditions, and vegetation will affect odor con-
ditions. A musty odor will be most pronounced immediately
following application of sludge, however, once sludge
becomes aerobic, the odor should dissipate.
3. Metro proposed to haul sludge around-the-clock in order to
fill sludge storage facilities at the Pilchuck site in the
shortest possible time, so that sludge could be applied in a
timely fashion and in the quantities needed. Metro has
indicated that nighttime hauling is preferred because of
greater flexibility in site operations. At least one
resident on Armstrong Road has indicated a desire for all
trucking to be done at night in order to avoid additional
traffic during the day.
4. A discussion of viral infection and vectors among wildlife
has been added to the Final EIS in the Wildlife section.
5. Metro has stated that a detailed operations plan would be
prepared relative to sludge handling and application. Such
procedures would incorporate safeguards and mitigation
measures to avoid adverse impacts.
Jeff Jfelley-Clarke
Senior Planner
JKC/scb
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OF
A
O
PUBLIC WORKS DEPARTMENT
RICHARD C. HOUGHTON • DIRECTOR
MUNICIPAL BUILDING 200 MILL AVE. SO. HENTON. WASH. 98055
206 235-2569
May 2, 1983
N)
BARBARA Y. SHINPOCH
MAYOR
Kathryn Davidson
Environmental Evaluation Branch M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Subject: Draft EIS - Municipality of Metropolitan Seattle
Slude Management Plan
Dear Ms. Davidson:
The City of Renton Public Works Department has reviewed this draft EIS document
and provides the following comments for your consideration:
1. It is important that no sludge waste be allowed to contaminate
areas described below (see map attached):
a. Springbrook Springs Watershed area, including private
lands easterly to Benson Road and southerly to
S.E. 212th Street.
b. Cedar River Valley - upstream from Renton's Liberty
Park to Landsburg, including all river valley lands
up to elevation 300' USGS.
2. We feel that a specific analysis should be prepared of the Impacts of using
Monster Road, Longacres Way, Grady Way and West Valley Road as the proposed
haul route for sludge enroute to 1-5 and 1-405 highways. While the volumes
suggested in the draft EIS are not unacceptable from a capacity standpoint,
large trucks do present significant operational problems. Thet-efore, at
each intersection along the proposed route we recommend a review of
geometric constraints such as turning radii, sigh distance, etc. and
operational constraints such as gap availability for turns, resultant
queues and overall delays etc. In addition, the capability of existing
pavement to handle the size and frequency of proposed loads needs to be
considered.
3. Perhaps the document should also include a review of alternative routes,
to reinforce the choice of the proposed route as being the most suitable.
4. Metro should be put on notice that they are obligated to do street
improvements on Monster Road, Monster Road Realignment to Longacres Drive
a portion of Valley Parkway and perhaps the new bridge across the P-l
-2-
Channel at S.W. 7th Street. Metro will be subject to latecomers charges
for a portion of the Traffic Signal improvements underway at Grady Way
and Thomas Ave. S.W. and S.W. 7th St. Hardie Ave. S.W. Over legal weight
operations are not allowed, and S.W. 7th Street 1s unable to handle heavy
loads.
Thank you for the opportunity to comment on this draft EIS. Please contact
this office if you require additional information.
Very truly yours,
Richard C. HoughtonC'
Public Works Director
cc: Mayor
R. Bergstrom
-------
Response to City of Renton Public Works Department Letter of
Hay 2, 1983
1. The existing composting site is within the Springbrook
Springs watershed area; however, modifications are underway
for upgrading the surface water collection system. These
modifications should adequately protect the stream from
adverse impacts caused by the composting site. Future uses
of sludge in both areas will be preceded by detailed
environmental assessments of the specific application sites.
2. Your request has been transmitted to Metro staff. In all
likelihood, such transportation studies would be a part of
the expansion program for the Renton treatment plant.
3. Comment noted and transmitted to Metro.
4. Comment noted.
GO
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CITIZENS
219
-------
220
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Response to Jean C. Davis Letter of May 28, 1963
KJ
1. A discussion of pathogens and organics has been added to the
Silvicultural use section of the EIS. A more detailed
discussion of site-specific factors relative to organics and
pathogens appears in the Pilchuck impact assessment.
2. A discussion of organics relative to composting has been
added to the Final EIS.
3. The discussion of Metro's project alternatives and back-
ground information on sludge handling was included in the
EIS because not all recipients of the EIS received copies of
Metro's plan.
Q
-------
N)
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Iv)
Response to Mrs. Marc Hayes Letter of May 31, 19B3
1. According to Duane Weston, the Citizens Committee, estab-
lished in December 1981, has a representative cross section
of community interests, including nearby residents.
2. Based on the evaluation of site characteristics and Metro's
proposed methods of application, the risk of water con-
tamination is judged to be low, particularly since
groundwater flows away from residential areas north of the
site and toward the south.
3. Odor should only be noticeable immediately following sludge
application. Once the sludge becomes aerobic, odor detected
off-site should be limited.
4. Any future application sites must be subject to the environ-
mental review process. Additionally, Metro has established
site selection criteria that limit unsuitable areas from
further consideration. Metro would evaluate all potential
sites using those criteria.
5. Metro would be required to follow operational procedures in
order to comply with Snohoraish Health District requirements.
6. Comment noted.
1. See response to comment number 1.
-------
Response to David L. Thomas Letter of May 30, 1983
Lrf
David L. Thomas
c/o Claarvlew A-^res
11225-2fl5th St, m
Arlington, WA 98223
May 30, 1983
Ka*-hryn Davidson
EPA, Region 10
1200 Sixth Ave.
Sea^-le, WA 98101
Dear Madam,
Regarding *he Seattle sewagn sludge project proposed for Pllohuok
Tree Farm's Amstrong Track area — Grandvlew Bd.t Please consider my
objections t0 that projec*:
I an a resident of ^hls ar»a, and I honestly do no* wan* vo find
out, af-er Its i-QO late, tha«- our environment will be affected adversely
— by foul air (odor) — or virus. These are mv personal objections.
1. Comment noted. See response to comments 2 and 3.
2. Ammonia will be volatilized as a result of spraying sludge.
This "loss" of nutrient value is minimized by applying
sludge directly below the ground surface through a tilling
procedure. Since the ammonia dissipates rapidly, it will
not cause an adverse air quality impact.
3. Use of sludge for soil reclamation and agriculture allows
for direct tilling into the soil. The silviculture options
do not allow direct cultivation because of the presence of
existing vegetation.
Wore objectively, I no*e in *he s^i^y «-ha* was made, t^ha*, of
every 700 Ibs of spray application of sludge, abiu*^ 500 Ibs was "
*o fhe atmosphere, thru "vola^lza^lon" . Sounds like a big loss rr> me,
and also a significant atmosphere pollutant.
Spraying *"he sludge may be efficient and all, but, regardless of
where !«• is applied - ay area or elsewhere - I would prefer tha«- i<- be
cultivated ln*o the ground rather than left on topi So jt wouid ^0 more
good and be less of a liability.
JUN 1 1333
ENVIROM!.!C:.rV i:..,LJ
fc.'..'....,-I
Sincerely,
David L. Thomas
i_ya_*i^J
-------
May 6, 1983
ro
to
Kathryn Davidson
Environmental Evaluation Branch M/S »13
Environmental Protection Agency
1200 Sixth Avenue
Seattle. WA 98101
Re: Pilchuck Tree Farm Sludge Management Project
Dear Ms. Davidson:
»e urge you to deny the approval of the proposed Municipality of Metropolitan
Seattle (Metro) Sludge Management Plan as it relates to the Pilchuck Tree Farm
Sludge Management Project.
We are concerned that the application of sludge in our community will result in
illness to animals, fish and hurnans in the surrounding area, and in the community as
a whole, because of exposure to bacteria, viruses and parasites which are contained
in the sludge and will be spread through the air, by physical contact or
contamination of groundwater. Sludge also contains heavy metals in concentrations
greater than are now in the soil which will accumulate to toxic levels in plants and
wildlife. We believe that eventually this will have a negative impact on our
community as a whole.
We do not believe, even with well-trained personnel, that this program can be
administered adequately because of the all of the unknowns and variables which are
yet to be investigated. We are not convinced that Metro and the Pilchuck Tree
Farm, even with assurances that they will follow correct and agreed-upon
procedures, can guarantee to our community that this exposure to sludge will be
safe to people living in this area.
Our other concerns are regarding the lowering of the value of property surrounding
the treatment area because of the introduction of toxins in the general area;
deterioration of our county and state roads because of heavy use by semi-trucks
daily in hauling sludge to our area; and traffic and safety hazards caused by the
introduction of this traffic to our rural community.
This project may benefit Metro and the Pilchuck Tree Farm, but we cannot envision
any positive benefits to this community by the introduction of King County's wastes
into our environment.
An. Lanny Vanderberg
24613 27th Avenue N.E.
Arlington, WA 98223
*35-5879
Wltf
Response to Mr. and Mrs. Lanny Vanderberg Letter of May 6, 1983
1. EPA has analyzed the proposed project based on the best
information available on community risks and sludge
application in a forest environment. The Snohomish Health
District, Washington Department of Ecology, and Metro will
ensure that the program is properly planned and carried out.
2. 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 demon-
stration project (Pilchuck Citizens' Advisory Committee
minutes October 1982). Also, the beneficial effects of
sludge application are consistent with one of the major
purposes of the Arlington area plan: to reinforce
management practices which would protect the long-term
productivity of the forest.
3. Traffic mitigation measures in the EIS include improvements
and maintenance considerations for Metro that would decrease
road deterioration and traffic hazards.
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-------
Response to Joan Witscher Letter of April 21, 1983
1. Apologies extended. Correct spelling has been incorporated
into the Final EIS.
2. The effects of sludge application on forestlands have been
studied at Pack Forest since 1974 and studies of human
exposure to sludge and sewage (primarily at wastewater
treatment facilities) have been carried out for a consid-
erably longer period of time. Data from those studies were
used to determine impacts likely to occur at Pilchuck.
|A< APR 27
-------
Hay 30, 1983
Response to DeWain C. Hergele Letter of May 30, 1983
1. Concern noted.
to
NJ
10
Kathryn Davidson, E.P.A.
Region 10
1200 Sixth Ayenue
Seattle, Washington 98101
Dear Kathryn Darldson,
This letter Is being written aa ay protest of the pro-
posed application of treated sewage sludge from Seattle to
the Pllchuck Tree Farm acreage In the Bryant, flrandvlew area
and the Pllchuck Tree Farm acreage Just off 115Ch Arenue N.E.
I do not want this filth sprayed on the land, and I |(J)
protest the action. |
Sincerely,
^ c
11225 - 285th St.N.E.
Arlington, Washington 98223
OHIO
JUM 1 1203
ENVIRONM.:;,'T'L y,'h
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Hay 28, 1983
Kayhryn Davidson E.P.A.
Region 10
1200 Sixth Ave.,
Seattle, Wa 98101
I am a property owner and live close to the area, where the
The Tree Para "Sludge" project has received endorsement from area
citizen, who do not live near the area*
I do hereby protest and an against the Sludge project
BetsyjH. Bolgen J
Craig SJolin
Kristie L. Sjolln
11021 Orandview Trail
Arlington, Wa 98223
Telephone 435-9724
JUN i ]8Q3
Response to Betsy R. Bolgen Letter of May 28, 1983
1. Concern noted.
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F.L. Binstock
11225 - 285th St. I.E.
Arlington, Wash. 98223
Response to Dixie E. Binstock Letter of May 30, 1983
1. Concerns and comments noted.
May 30, 1983
to
U>
Kathryn Davidson, E.P.A.
Hegion 10
1200 Sixth Avenue
Seattle, Washington 98101
Be: PROTEST of the application of treated sewage sludge
fron Seattle to the Pllchuck Tree Para acreage in
the Bryant-Grandview area north of Arlington.
Dear Kathryn Davidson,
I an writing this letter of protest, in behalf of both
•y husband and nyaelf. We are long-tine residents in the
Bryant area and we do not want this treated sludge applied
to the trees or anything above-ground.
Please STOP the further progress of the action toward
applying that sewage filth to the land In our area.
Sincerely,
Dixie E. Binstock
(Krs. Philip L. BlBStoclr)
JUN 1 1903
ENVIRONMENTAL EVALUATION
BRANCH
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TO;
3 7, / 7*3
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Response to John Lala, Jr. Letter of May 27, 1983
1. The effects of sludge application on forestlands have been
studied at Pack Forest since 1974 and studies of human
exposure to sludge and sewage (primarily at wastewater
treatment facilities) have been carried out for a consid-
erably longer period of time. Data from those studies were
used to determine impacts likely to occur at Pilchuck.
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Response to Thelma and Brian L. Hayes Letter of Hay 28, 1983
1. Comments and concerns noted.
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Response to Merolyn Dahl Letter of May 28, 1983
1. Concerns and comments noted.
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Response to Lisa Creton Letter of June 1, 1963
1. EPA has analyzed the proposed project based on the best
information available on community risks and sludge
application in a forest environment. This analysis has
included evaluation of public health, wildlife, and fish
resource.
2. Traffic would increase by 4-9 trucks per day. This
projected traffic increase would have no measurable impact
on either State Route S30 or State Route 9 capacity or cause
an inordinate amount of roadway deterioration. Armstrong
Road and Brakken Road are more susceptible to deterioration,
and periodic cooperative maintenance checks and repairs by
Metro and Snohomish County should be carried out as a
mitigation measure.
3. Odor should only be noticeable immediately following sludge
application. Once the sludge becomes aerobic, odor detected
off-site should be limited.
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10
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JUN 1 1SS3
eiTAffl
BRANCH
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Response to Shain Thompson Letter of June 1, 1963
1. The effects of application of sludge on land have been
studied since the early 1970s by the EPA, other federal
agencies, a number of universities, and a variety of
municipal sewerage districts across the country. Those
studies have included such aspects as the fate and effect of
pathogens, heavy metals, and other constituents of sludge;
effects on wildlife and public health; and a variety of
other issues. EPA has analyzed the proposed project based
on the results of those studies.
to
00
MAY 181S33
Kay 17. 1983
.
L.lV.ri
John Hauberg
Pacific Denkanann Co.
Grand Central on the Park Bldg.
Seattle 9810U
1000 NW Northwood Road
Seattle 98177
Rei METRO Sludge Management Plan
Dear Mr. Haubergi
We are writing to express our outrage that you have made a
proposal to Metro to spray your trees at Lake Armstrong with
hospital and human waste.
As you will recall, my Mother, Mrs. Bertha S. Olson, was to have
her Lake Armstrong and surrounding property condemned by Right
of Eminent Domain by Snohonish County for purposes of a garbage
disposal site. In her desperation and the great love that she
shared with my Father for the Lake and the extraordinarily large
"pot holes", she appealed to you for help in halting these con-
demnation proceedings. My Mother even had my Father buried close
to his "pot holes" which is now Pilchuck Tree Farm. The eventual
sale to you was somewhat softened by your assurance to my Mother
that "you would take good care of her property for her". At the
time you were assuring an "eccentric old lady" that you would
only expand your tree farm and not disturb the environment, were
you then entertaining plans to polute the entire area to enhance
your timber production?
We are starting a vineyard on a portion of my Mother's property
featuring the Mueller-Thurgau wine grapes from the Bainbridge
Island Vineyard and Winery. We have <*50 plants in the ground
and plan to have 1000 vines next month. We are depending on
the springs that flow underground in the area to irrigate the
vineyard and of course, for drinking purposes. Pursuing this
scenario, perhaps our grapes and/or investment will not even
be marketable due to the proximity to your toxic drenched trees.
Naturally, we feel that our Investment is every bit as important
as the Pilchuck Tree Farm and that we should be more responsible
neighbors.
The EPA Plan refers to utilising up to 38 trucks per day to
deliver the toxic sludge to your property. The absurbity of
huge trucks negotiating the one-way switch back road traversing
the railroad track boggles the mind. As you know, the hill was
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CO
VQ
Page 2
so hazardous that a flashing red light had to be installed to
warn oncoming cars not to proceed until clear. The roadway
is not good in the winter months with normal traffic, but
you would place the burden of road repairs on the taxpayers
in order to hasten the growth of your trees for profit.
Indeed!
Mr. Mauberg, we plead with you as a man of integrity, principal
and as a concerned human being and neighbor, to cancel your
request to Metro to use material that may injure or kill human,
plant and animal life on our idyllic setting at Lake Armstrong.
Respectfully submitted,
EUNICE and HERBERT BOLIE
Four Cedars Vineyard
25519 Lake Armstrong Road
Arlington, tfa. ,98223
10197 NE South Beach Drive
Bainbridge Island, Wa., 98110
81*2-5839
Earl Rice, Metro
Kathy Davidson, EPA
.liihi
'I'M l.l.unl I rlih.ll limlclm^
Itf l£Jf -lt
til il 1 Mi
Mlllr U \ !!SIIII
Irl .Jill, i lii.l I.'.S^
May 19. 1983
Mr. and Mrs. Herbert Bolie
2rjf)ll) Lake Armstrong Road
Arlington, WA 98223
Dear Mr. and Mrs. Bolie,
I am pleased to respond to your letter of May 17. Complete
information is always needed on which to make judgements and decisions.
1 can, in this letter, add lo your information, but I do not yet
have complete information. Nor does the Sludge Project Advisory
Committee which is counseling both our Tree Farm and Metro. But
we are all doing our best to get answers to all questions before
any license to proceed is requested or granted by Snohomish County.
Uul our Tree Farm did not ask Metro to spray sludge on our
land and trees. Metro brought the proposal to us and we have expressed
great interest in it. We have encouraged the formation of a neighborhood
citi/ens group to seek out all the facts, pro and con, about the
proposed project, and advise both Metro and us as lo the conclusions
driiwn from the tads.
I believe the Advisory Committee is the group to which you
:>liould be addressing your concerns. To that end, I am forwarding
youi Idler to our chief forester Duane Weston who din give it lo
llu- kormnillee. We do not w.inl to pollute ground water, the soil,
CM iliL- .11r either and are a-idresaing our concerns to the Committee.
Sincerely yours,
JllllAich
Copies to: Duane Weslon
Earl Rice
Kathy Davidson
Tvfir»r:
MAY 20 1983
iM LVhLUAIlON
BRANCH
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Response to Eunice and Herbert Bolie Letter of May 17, 1983
K>
*>.
o
Based on EPA's review of topographic and area maps, the
proposed sludge application site would be located
1.0-1.5 miles from the vineyard; the sludge storage basin
would be approximately 0.75 mile. The groundwater beneath
the application site is geologically isolated and does not
contribute to the vineyards groundwater supply. Groundwater
beneath the sludge storage basin does travel toward Harvey
Creek and Lake Armstrong; however, no adverse impacts on
that groundwater supply are projected from sludge loading
and unloading activities or from spraying of rainwater
collected in the storage basin after completion of the
application project. Based on EPA's analysis, the proposed
project will not adversely affect the vineyard.
Metro's sludge is not classified as a hazardous or toxic
waste. Four to nine trucks per day would be used during the
summer months for delivery of sludge to the Pilchuck site;
if delivered during the winter months, approximately
13 trucks per day for 15-20 days would be needed to fill the
storage lagoon. Sludge trucks (28-cubic-yard capacity) have
had no problem negotiating Armstrong Road. It has been
recommended that an improved advance warning device be
installed to ensure that adequate warning is provided.
Additionally, it has been recommended that Snohomish County
and Metro establish a cooperative road maintenance program
for Armstrong and Brakken Roads.
~a> &u,
L 0L MA) 0
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Response to Glen Kiese Letter of May 19, 1983
NJ
1.
2.
A discussion of the impacts of sludge application on wild-
life, surface water, and groundwater was provided in the
Draft EIS and reprinted in this Final EIS.
A cooperative Metro and Snohomish County road inspection and
maintenance program has been recommended as a mitigation
measure in the Draft and Final EISs.
MAY 31 1093
ENVIF.ONMrrir.'L EV.UUAI'.ON
ifM.W
-------
Response to Mr. and Mrs. Dennis Somerville Letter of Hay 31, 1983
Based on studies conducted at the University of Washington,
Pack Forest, sludge or constituents in the sludge will, not
run off the application sites in quantities -sufficient to
contaminate surrounding areas. The flat terrain, depth to
groundwater, and properties of the soils are all factors
that would limit sludge movement off-site.
Incineration has been evaluated by Metro and does not
represent an alternative that is preferred because of high
cost and energy requirements. Metro has chosen to defer
further consideration of the incineration alternative until
some future time.
NJ
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etfcVf et^-.u
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MAY 31 K33
ENVIRONMENTAL CVALUAflOM
LUJ
Response to Mr. and Mrs. Allen Janise Letter of May 30, 1983
1. Anaerobic digestion (treatment) of sludge is recognized by
EPA as a treatment process which significantly reduces
pathogens. The combination of anaerobic digestion and the
closure period following application of sludge would reduce
pathogens to low levels. Tables 3-18 through 3-22 indicate
the quantities of materials which must be consumed at any
one time for them to be harmful.
2.
Comments and concerns noted.
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Response to Ruth Pfeiffer Letter of May 28, 1983
1. See response to letter from John Lala Jr.
NJ
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/
M/W 31 1S83
fNVIftONMENIAl [VAIUAIION
BRAt.'CH
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to
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UI
Virginia. Hayes
11009 Gnandvieui Tnail
Arlington, WA. 942Z3
Katimyn Davidson E.P.A.
Region 10
1200 Sixth Aue.
Seattie, Wold. 9SJO/
To Whom it May Concenm
MAY 3112W
'•tfliRCKtF.Wip.i- i
Ai a citizen who lives in the. anea 06 the. pnoposed iludge. application,
1 am veny much opposed to its being applied in this beautiful anea that I
chose, to neside in some, yeans back. I £ind that this it an in^ningment upon
my nights to choose not to be. exposed to the. txcJieta (tntated on untn.e.ated\
0|J people uiho do not even n&side dose, to oun. anna. o< Aldington. I would not
even dind it desinable to have, it collected finom the. piople. 0(j my own home, town
and Aptayzd and &tone.d by my home..
I'm sune that you and youn. organization have, heand it all finom those. o$ us
who would be living dine.ctly in the. anea 0|j this "Supet Poope* Spnay", but 1 fan
one, am not go-ing to just "let it happen" became Metto needi a p£ace to dump thein
waste and Philchuck Tne.e Fanm wants thein tnees to gnow fasten so the.g can have a
quicken netunn on thein money fanom the sale ofa these. tAe.es.
It leemi to me and othens that one. opposed to this pnoject, we just may
be the Guinea pigt , in a tense, to be used as wastable people, to pnove whether
on not the E.P.A. is night in thein findings neganding sludge, and its safie use..
Thene is no scientist, at this time, 'who fenowi all tiie liabilities that one in-
volved with the bac.te.nis, Ifenoiun and unfznown) ainbonn vinus and most panticulanly
the. vinus A.I.P.S. {aquined immune di^iciency Ayndnome). This latten. virus in itself
is one. Oj{ the most necent and unfenown ejects that has come to the attention o& man
and I do wot wish to be. exposed to any po&tible contaimination. This may be a real
laughable statement to some individuals because. o& the. most widely accepted .teaAoiw
that one aquines this dteaded disease., but T am pointing out the ve.ny possible
unknown viaud o
Thank you. fan youn attention in ne.ading this letteA.
Response to Virginia Hayes Letter of May 31, 1983
1. Comment and concern noted.
2. See response to letter from John Lala, Jr. Please see
Table 3-19 for an analysis of quantities of material which
must be consumed at any one time to result in enterovirus
infection.
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N>
We tte undersigned wish to inform tbose responsible for the Metro
SLUDGE TiiiTIhG program on the Pilchuck Tree Farm, that we absolutely
oppose the TESTING in this area. We feel that this would be a
nuisance as well as a health haeard to man and the wildlife in the area,
and is a threat to our land value in the future.
1.
=•0
Wo the undersigned wish to infora, those responsible for the Wc-tro
aLUUUK TOTING program on tne I'ilchuck Tree Farm, that we absolutely
^ppose the TJBWhG in this area. We feel that this would be a
imisouce as v,ell as a health haaard to man and the wildlife in the arc-
unil is a threat to our land value in the future.
9.
10.
11.
AJ.E.
14
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17
18.
19.
20.
2l
22.
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10.
IV.
id.
24.
26.
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We tnn uaderilgnnd with ta Inforn tbaaa reipvnilbla far tba Katra
SLUOia 'iiiSTlHQ pragran »r. (be Pilchuek Tree Farn, that wa are
ab»alutely appaied ta tba T-STINtt In tbli area. Ws foal tbat thla
vauld bn a nuliance a> wall at a bnaltb hazard t» man and the vlldllfa
la tbe area, nnd It a threat ta «ur laad Talus In tba futura.
NAKB
ADDH2SS
£— o o 3 - z. ?.
15.
16.
17.
SLUDGE TESTING program on the Filcbuck Tree Farm, that we absolutely
oppose the TESTING in this area. We feel that this would be a
nuisance as well as a health hazard to man and the wildlife in the area,
and is a threat to our land value in the future.
ADDRESS
f,.^ / X/X/7
. T^Lf,.-;?* //£i^t/, ^
16.
17.
18.
igT
20.
21.
22.
23T
21.
22.
26.
-------
We the undersigned wish to inform those responsible for the Iletro
SLUDGS T&bTIKG program on the Pilchuck Tree Farm, that we absolutely
oppose the TESTING in this area. We feel that this would be a
nuisance as well as a health ha&ard to nan and the wildlife in the area,
and is a threat to our land value in the future.
NAli*
AUDReSS
^ -T
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'( > Mr' »TA
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We the undersigned wish to inform those responsible for the Ket o
SLUDUli a'tb'i'lhG program on the Pilchuck Tree Farm, that we absolutely
oppose the TJfe'riliG in this area. We feel that this would be a
nuisance as v-ell as a health haaard to man and the wildlife in the area,
and is a threat to our land value in the future.
1.
7 -
2.
a
11.
If.
ly.
20.
21.
22.
24.
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Ae the unilersignod. wish to inform those responsible for the i..etro
oLUjJGai 'i'jio'l'mij program an the^tilchuck Tree *arra, that we are absolutely
opposed to the j-JiJij.no in this area, -e feel that bhis would be a
nuisance as well as a health h^ard to man and the wildlife in the area,
aua ia a Ua-oau b«j our laud value in tne future.
iV\t ur»d.tr signed vfiiVi to inForm iHese
the
Tret
cm
, -tv%aV v4e <*rt cxbioUVUy opposed
iiv'-Vv»;s Qftcx. Yle £tt
-------
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We lb« unl^riigQcd with t* lof»r» tbtie rotptanlblr f»r the Motr*
SLUMS '!' STIMi> prtgru «n the Pllehu«k Tr»» K»r«, Ihiit we •« «b»»-
lutaly *pp*ied t. tba TSSXII.U La thl. »re«. We fool thit thlt would
b< a cultanca at well a> n health hasnrd t* aaa nnd the wlldllf*
In the araa. and la a threat ta auf land Talua In ttas futura.
e
11.
13.
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>Vo the under.slened wish to inform those responsible for the Metro
SMUiUK TjSsTJLhG program on the PilchucJc Tree Farm, that we absolutely
,pppose the l'Jib'£Ll
-------
We the undersigned wish to inform those responsible for the Metro
tiLUDGii -TjuaTIftG program on the Pilchuck Tree Farm, that we absolutely
oppose the MSTIMG in this area. We feel that this would be a
nuisance as v.ell as a health hazard to man and the v;ildlife in the area,
and is a threat to our land value in the future.
1,.
5.
6.
7.
to —
Ln 8.
9.
10.
11.
13-
14.
IVe the undersigned wish to inform those responsible for the Metro
tJLUDGi; TJib'i'lWG program on the Pilchuck Tree Faro, that we absolutely
oppose the TESTING in this area. We feel that this would be a
nuisance as well as a health hazard to man and the wildlife in the area,
and is a threat to our land value in the future.
2.
3.
4.
13.
14
'S-tA>{ Ctrl.
a,/'.
16.
17-
18.
16.
17.
18.
21.
20.
21.
22.
24.
21;.
'26.
24.
21;.
26.
-------
We the undersigned wish to inform those responsible for the lletro
SLUDGii WiiiTIMG program on the Pilchuck Tree Farm, that we absolutely
oppose the TESTING in this area. We feel that this would be a
nuisance as well as a health haaard to man and the wildlife in the area,
and is a threat to our land value in the future.
le.
.
16.
17.
18.
19.
20.
2l7
22.
*4*4=-
'
iVe the underaiBned wisa to inform those responsible for the Metro
aLUJOUJi TtoTlftG program on the Pilchuck Tree Farm, that we absolutely
Oppose Che TJiii'WhG in this area. We feel that this would be a
nuisance as well as a health hazard to man and the wildlife in the,- area,
and ia a threat to our land volue in the future.
Vf x ^ /.-. t g /fr-. ^<^/
c'l.
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Cl N Vi T.-r.. C?. (A,
24.
26.
.'0.
-------
We the undersigned wish to inform those responsible for the Metro
SLUDGE. TiaTItiG program on the Pilchuck Tree Farm, that we absolutely
oppose the TESTING in this area. We feel that this would be a
nuisance as well as a health hasard to man and the wildlife in the area,
and is a threat to our land value in the future.
NAttiS
13.
16.
18.
19-
20.
21.
22.
24.
26.
AJJDRfi'SS
l•
^?3
We the undersigned v/ish to inform those responsible for the Metro
riLUJJGli; TKsTliiG program on the Pilchuck Tree Farm, that we absolutely
joppose the TES'MivG in this area. We feel that this would be a
•nuisance as well as a health hazard to man and the wildlife in the area,
,:and is a threat to our land value in the future. ^
NAkK
. flj.
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yntifyAc.lt--
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/£//a^W^A^tf9f22.
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M
We the undersigned wish to inform those responsible for the Metro
ijLUiAin 'i'je^>'i'li\(j program on the Pilchuck Tree Farm, that we absolutely
oppose the 'JKb'flftG in this area. We feel that this would be a
nuisance us v.ell as a health huaord to man and the wildlife in the area,
and is a threat to our land value in the future.
Wo the undersigned wish to inform those responsible for tba Metro
tiJLUJJGJS 'I'uxL'iKG program on the Pilchuck Tree Farm, that we absolutely
^ppose the MbU'lhC in this area. We feel that this would be a
nuisance us well aa a health hazard to man and the wildlife in the arc.,,
and is a threat to our land value in the future^
1.
3. -
11.
14.
16.
17.
Id.
7/
21.
21.
24.
2%~
26.
-------
Response to Petitions
1. Concerns noted.
LEAGUES OF WOMEN VOTERS IN KING COUNTY
14D6 EIGHTEENTH AVENUE
SEATTLE. WASHINGTON 98122
JIW
to
U1
Ul
Hay 25, 1983
Marilyn 0. Monk
Sludge Program
Municipality of Metropolitan Seattle (METRO)
821 Second Avenue
Seattle, Washington 98104
Dear Ms. Monk:
The three Leagues of Women Voters in King County appreciate the opportunity
to comment on Metro's Draft Sludge Management Plan.
While most documents which League reviews deal with proposals which could
pose potential new risks to the environment, the topic of sludge management
differs in that it deals with choices for managing a substance whose produc-
tion is already an established fact and whose disposal has always posed some
degree of risk. In fact, when marine dumping and other sludge disposal
practices of the past are recalled, it seems as though we as a nation and
as a local community have "nowhere to go but up" in making changes in these
practices. Nevertheless, it is important to proceed with care, to assure
that the new practices don't simply substitute new hazards for old ones.
League has a long-standing commitment to recycling, which inclines us to
favor those strategies which involve the beneficial re-use of sludge as a
"resource," provided the environment and human health can be adequately
safeguarded. Metro is clearly moving in this direction in its proposed mix
of disposal methods.
However, League is less Concerned with the precise mix of new and continued
recycling and disposal technologies than it is with the process by which
such decisions are made. In this regard, Metro, through its 201 planning
study and through direct experimentation, appears to have studied the tech-
nologies to an extent which offers fairly good assurance that any signifi-
cant problems with the technologies would be discovered and addressed.
In addition, Metro has made a very noteworthy effort to inform citizens
about the management plan as it was being developed and to solicit their
input, we believe it was a particularly good decision to hold public hear-
ings not only in Seattle, for King County residents, but also in the locality
affected by the experimental silvaculture applications in Snohomish County.
We are similarly gratified to know that Metro is committed to conducting
separate public review processes for any future site-specific project pro-
posals.
-------
M
Ul
Finally, we find it reassuring that the draft plan contains a broad range
of disposal options and a timetable which allows for future, re-evaluation.
refining of plans, and shifts in emphasis if one or another of the chosen
options doesn't work out as planned. We hope that the agency continues to
be responsive both to citizen concerns and new scientific data regarding
sludge management projects.
League is not only committed to recycling but also, wherever feasible, to
waste reduction at the source. Source separation and reduction becomes
even more important when hazardous substances are involved. Therefore we
view with great interest the possibilities mentioned on pp. 3-10 of the
draft management plan such as a requirement for industrial pretreatment to
remove heavy metals, consolidation of industrial flows by Metro, or any
other programs aimed at separating out toxic substances and rendering the
recyclable product safer for widespread public use.
Sincerely,
Re8ponse to Comments From League of Women Voters in King County,
Letter of May 2S, J9fl3
1. Comments noted.
Charlotte Mats en
Margaret Coloney
Co- Presidents
League of Women Voters
of Lake Washington East
Colleen Rowel1
President
League of Women Voters
of Seattle
Bonnie Shride
President
League of Women Voters
of King County South
CR:bw
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Appendix A
Public Health
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Appendix A
PUBLIC HEALTH
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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 constituents not detected: 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).
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.
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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
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).
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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.
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
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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.
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
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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).
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 mg
of chromium. No particular tissue retains high concentration
levels. Chromium can accumulate in the lungs with age, but the
levels are usually harmless.
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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) .
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
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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 of 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.
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) .
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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.
Lead toxicity in animals occurs when the dietary intake
approaches 30 mg/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.
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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) .
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).
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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 moTybdenum 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
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).
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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) .
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) .
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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.
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
A-14
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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 *m. 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) .
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 1982 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).
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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 *m. The bacteria are motile at 22-25°C and nonmotile at
35-378°C. Yersinia enterocoliticia bacteria are found in
domestic and wild animals and are transmitted 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.Point's digested, dewatered
sludge has a mean value of 0.15 x 10 MPN/100 g of Y.ersinia
enterocoliticia and Renton's raw, waste activated sludge has a
mean value of 0.36 x 10 MPN/100 g of Yersinia enterocoliticia
(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 *m. 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 tuberculosTs 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).
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Mycobacteria levels were monitored at the West Point and
Renton's Treatment Plants from June 1981 to August 1981 (Metro
unpublished data). The mean mycobacteria level in West Point's
digested, dewatered sludge was 2.0 x 10 colony-forming units
(CPU) 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. in 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 (Surge 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) .
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).
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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 *m in diameter
(Burnett and Schuster 1973). The bacteria are gram-positive and
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 (Munger 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
hazard's 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.
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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 iri 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).
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, upper 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
A-19
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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).
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.
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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
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.
comm.).
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
A-21
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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 in Bitton et al.
1980) . This insecticide is highly toxic to aquatic organisms,
avian, and mammalian species.
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) .
A-22
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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) .
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.).
A-23
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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).
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).
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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.
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).
A-25
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A-26
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Appendix B
Properties of Forest Soils
-------
APPENDIX B
PROPERTIES OF FOREST SOILS
B-l
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B-2
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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
El
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 and
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
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
B-3
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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
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
B-4
-------
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. While 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) .
A small percentage (about one percent) of this organic
nitrogen is hydrolyzed annually 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
NO.,- is fierce, with bacteria utilizing most of this anion. The
remainder is taken up by vegetation and only a small amount is
leached from the soil.
B-5
-------
to
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
NO0-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.
-------
NITROGEN CYCLE OF AN UNFERTILIZED CONIFEROUS FOREST
V
Leaching Loss
0.4 Ibs
FATE OF SLUDGE-ADDED NITROGEN AFTER YEAR 1 (1* SLUDGE)
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)
B-7
-------
The addition of 1 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 be lost as a gas (volatilization).
That loss would occur from the lagoon (if one were used), during
application and after sludge application. Estimates are that
volatilization loss is about 50 percent of the available (NH.,,
NH.+) nitrogen during the first year (Henry and Cole, 1983; EPA,
1977).
Additional pathways for available nitrogen include plant
uptake, soil storage, and nitrification (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. iri Sopper and Kerr, 1979) .
Increases in the nitrification 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 quantification of nitrogen fluxes within the forest
environment is difficult to determine precisely. Many factors
play a role in the nitrogen cycle and are not totally
understood. Site-specific characteristics such as vegetation,
microclimatic conditions, and soil variables will influence
rates and quantities within the cycle. Other factors such as
initial concentrations, application technique, and storage times
and methods also influence the cycle. These factors have been
approximated in Figure B-l, a conceptual model of the nitrogen
cycle.
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.
B-8
-------
Table B-2
Nitrogen Balance for Years Two, Three, and Four
Following a One-Inch Sludge Application
To a Western Washington Coniferous Forest
Year One
Applied Organic-N
Applied Ammonia-N
Mineralized N
Tree Uptake
Volatilized
Leached
Year Two
Available N (storage)
Mineralized N
Tree Uptake
Volatilized
Leached
Year Three
Available N
Mineralized N
Uptake
Volatilized
Leached
(storage)
Year Four
(1,540) pounds/acre
+ 440 " "
+ 305
- 100
- 370
- 75
200 pounds/acre stored,
1,235 pounds/acre
organic-N remains
200 pounds/acre
+ 50
•150
0
25
75
pounds/acre stored,
1,185 pounds/acre
organic-N remains
Available N (storage)
Mineralized N
Uptake
From: Metro 1982c
All values are approximate
75 pounds/acre
+ 30
-105
0 " "
0 " "
0 pounds/acre stored,
1,155 pounds/acre
organic-N remains
0 pounds/acre
30
30
0 pounds/acre stored,
1,125 pounds/acre
organic-N remains
B-9
-------
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 in Sooper and Kerr 1979;
Williams et al., 1980).
B-10
-------
Table B-3. Soil Samples Analysis of the Pilchuck Site
Parameter
Soil
Organic-N
NH -N
NCC+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
mg/kg
mgAg
mgAg
mgAg
mgAg
mgAg
Mean
(n = 12)
0.312
.0061
.0060
.26
.023
.054
77
20
5.6
1.6
40
13
.22
45
21
59
Minimum
0.52
.0009
.00051
.086
.0052
.035
56
9
5.0
.9
29
9
.14
25
9
41
Maximum
1.31
.010
.017
.726
.051
.084
88
45
6.4
2.3
59
17
.40
65
42
74
MPN/100 g
wet weight
MPN/100 g
wet weight
MPN/100 g
.36 x 105
<.38 x 102
<.33 x 103
.79 x 10
<.2 x 102
<.2 x 102
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.
.24 x 10
.24 x 10'
.7 x 105
B-ll
-------
Table B-4. Soil Samples Analysis Results of the Pilchuck Site
to
i
M
to
Until
iAurvC ti»«u«i
DCiOUrrtON
1 Tf-l 0-J"
I J-ll-
> .-If
« 11-41-
> Tr-1 o-ll"
« 11-11"
1 11-11"
1 Tf-IJ 0-1"
» 1-H-
•• 14-11"
11 Tf-ll O-ll"
" 11-41"
" TF-I» 0-«"
'« 4-u-
'» 11-11-
'• 11-11"
11 Tf-ll 0-1"
'• 1-11"
l»
10
til
fine
HI
1.0
*.i
1.1
1.1
4.1
4.1
1.1
4.1
1.0
1.1
1.1
1.1
».»
4.4
4.1
_JUL
4.4
_1J_
wiuimlmj
cm
111
(•» id
tc
<0.1
,
I
1
I
1
1
I
4
1
1
1
1
1
1
1
I
1
1
4
Ab 0.,
t«a
K
1.1
Cd«
0.14
-------
In general, researchers have not found metals introduced by
sludge to move below the top few inches of soil. Parker et al.f
(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,
B-13
-------
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 microbial 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) .
B-14
-------
Appendix C
Silviculture History Pilchuck Site
-------
Appendix C
SILVICULTURAL HISTORY PILCHUCK SLUDGE
APPLICATION SITES
C-l
-------
C-2
-------
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
C-3
-------
C-4
-------
Appendix D
Endangered and Threatened
Species Pilchuck Site
-------
Appendix D
ENDANGERED AND THREATENED SPECIES
PILCHUCK TREE FARM DEMONSTRATION SITE
D-l
-------
D-2
-------
JOHNSPELLMAN ^%*3P^ FRANK LOCKARD
Governor N^if^/ Director
STATE OF WASHINGTON
DEPARTMENT OF GAME
600 North Capitol Way, GJ-11 • 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 DC;to Base for informa-
tion on significant natural features in the study ^r.ea. At this time we
do not have information on special animal species in the immediate area.
Since information is being added to the files doily, i search at some
later date nay be worthwhile. Please keep this in :-;ino 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 .71 ere
tnorough research. Data in the Natural Heritage Data dase are limited to
significant observations of species of concern only. Significant observa-
tions are primarily comprised of breeding site ciata, 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
Olytnpia, 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
KRM:hl
D-3
-------
STAT^
Department of Natural Resources
OLYMPIA, WASHINGTON
98504
BRIAN BOYLE
CommUiiouer of Public Land
December 20, 1982
WASHINGTON NATURAL HERITAGE PROGRAM
3111 Seminar Building (SE 3109)
The Evergreen State College
Olympia, Washington 98505
Mr. Robert A Denman
Jones and Stokes Associates, Incorporated
1802-136th Place N.E.
Bellevue, Washington 98005
Subject: Pilchuck project site
Dear Mr. Denman:
We have completed a search of the Natural Heritage Data System for your study area.
At 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
D-4
-------
JONES & 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
D-5
-------
JONES & STOKES ASSOCIATES. INC. / 1802 136TH PLACE, NE / BELLEVUE. WA 98005 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,
Robert A. Denman
RAD/as
Enclosure
D-6
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
M/S 443
Mr. Joseph Blum
U. S. Fish and Wildlife Service
Endangered Species Team
2625 Parkmont Lane
Olyropia, 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 Pi 1 chuck 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
D-7
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Endangered Species
2625 Parkmont Lane S.W., B-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
FEB 1 4 1383
ENWU
D-8
-------
Your interest in endangered species is appreciated.
Sincerely,
;y
-/Jim A. Bottorff '
Endangered Species Team Leader
Attachments
cc: RO (AFA/SE)
ES, Olympia
WDOG, Non-Game Program
WNHP
D-9
-------
LISTED AND PROPOSED ENDANGERED AND THREATENED SPECIES AND
CANDIDATE SPECIES THAT MAY OCCUR WITHIN THE AREA OF THE PROPOSED
SLUDGE MANAGEMENT DEMONSTRATION PROJICT - 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
D-10
-------
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 FWS 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 FWS 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 projectsj/ 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 ISO 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 corrmitment 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 ccnstruction 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, Netional Marine
Fisheries Service, State conservaticn departments, universities and others who
may 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 EIS) 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.
ATTACHMENT B
D-ll
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D-12
-------
Appendix E
Cultural Resources Pilchuck Site
-------
Appendix E
CULTURAL RESOURCES PILCHUCK TREE FARM
DEMONSTRATION SITE
E-l
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E-2
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JONES & STOKES ASSOCIATES. INC. / 1802 136TH PLACE, NE / BELLEVUE, WA 98005
January 10, 1983
206/641-3982
Dr. Robert Whitlam
Office of Archaeology and Historic Preservation
111 West 21st Avenue, KL - 11
Olympia, WA 98504
Dear Dr. Whitlam:
Subject; 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 ta'sk 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
E-3
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IOHN SPELLMAN \W&+9/J 'ACOB THOMAS
Governor N^J?;^ Director
STATE OF WASHINGTON
OFFICE OF ARCHAEOLOGY AND HISTORIC PRESERVATION
777 West Twenty-First Avenue, KL-n • Olympic. 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
Enclosure
E-4
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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
E-5
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TABLE OF CONTENTS
Project Location 1
Proposed Act ions 1
Environmental Setting.. 3
Cul tural Sett ing k
Results of Literature/Archival Review 8
Qn-s i te Assessment 9
Resu Its 11
Recommendat ions 12
References Cited 14
LIST OF MAPS
MAP 1. Vicinity map and location of isolated finds 2
MAP 2. 1890 GLO Plat Map 6
E-6
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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: (l) 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. 24, 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 site
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 (41 by 58 meters), and a maximum design sludge depth of 15 feet (4.5
meters). Additional area would be required for the external berm slope and
E-7
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w
i
00
ARLINGTON EAST. WASH
rife 4 M4KOJVII1L 15 OUAOMANOLE
NJ80/ 5--W1 ^200/7 5
1956
UU*OR«NC,U LOCATION
MAP 1. Vicinity map of project area showing locations of isolated finds (numbered)
in relation to (a) lagoon site and (b) application area.
-------
3
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
Sti1laguamish 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 siIvicultural 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 precommercial1y thinned to
E-9
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350-1*00 stems per acre. The southern portion of this 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
precommercially 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 ursinus), 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.
E-10
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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 iS/Os when settlers began to take up the land.
While settlement of the Sti1laguamish Valley began at the mouth of the
river in 186A 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 188A 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 1926:517).
E-ll
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MAP 2. 1890 GLO Plat Map of project vicinity,
E-12
-------
The woman referred to is Mrs. Col 1ingwood, whose party passed the
proposed project area in 188A, 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
E-13
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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 Darrlngton 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 C«5-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 1961? Kidd 1964; and sites
recorded by Mattson in 197^, 1980 and by Onat 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,
E-14
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possibly dating to an early period. Many of these sites are located on
terraces, above major rivers (Stilson and Chatters 1981:14-21). 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
Stillaguamish 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
sensitive.
Reconnaissance of the proposed sludge application sites consisted of
walking the edges of the bluffs above Rock Creek, Kunze Creek and the
Stillaguamish River. These bluff edges had remained relatively undisturbed
E-15
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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.
E-16
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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 10 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 1). A total of seven bottle fragments, representing two bottles, were
found at the proposed sludge application site, and three artifacts,
including 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.
E-17
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12
Location ls Cobble Chopper. T 32N, R 6E, NE 1A, SW 1A, Sec.
T9~]with~m northern sludge application area along an existing
skid road near T.B.M. #21, .5 kilometers southeast of northwest
property gate and 53.6 meters east of Rock Creek.
Location 2i Flaked Basalt. T 32N, R 6E, NE lA, SW 1A, Sec. 19,
at extreme south end of northern sludge application site on a
point overlooking the Sti1laguamish River at the end of an access
road, .3 kilometers southeast of Location 1.
Location 3» Cobble Chopper, T 32N, R 6E, NE lA, NW lA, Sec.
JQ~. within" southern sludge 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
Stillaguamish River, near T.B.M. fk and Well #3.
Location At Bottle Fragments, T 32N, R 5E, Sec. 2k, situated in
the organic soil layer at the proposed sludge lagoon site, .3
kilometers north of the crossroads and 10 meters west of the road
which borders the powerlines 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.
E-18
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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. |t 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.
E-19
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REFERENCES CITED
Anderson Map Co.
1910 Plat Books of Snohomish County - compilation.
General Land Office
1890 General Land Office Plat Map, T 32N, R 6E5 T 32N, R 5E and Survey
Field Notes. Microfilm, on file Department of Natural Resources,
Bureau of Surveys and Maps, Qlympla.
Kidd, Robert
19&i» £ synthesis £f western Washington prehistory from the perspective
of three occupation sites. Unpublished Masters Thesis, Department
o? Anthropology, University of Washington.
Lane, Barbara
1973 Anthropological Report on the Identity, Treaty Status, and
Fisheries of the Sti1laquamish 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.
Phi 11ips, James W.
1978 Washington State p 1 ace names. l»th printing. university of
Washington press, Seattle.
Stilson, M. Leland and James C. Chatters
1981 Excavations at A5-SN-48N and 1»5-SN-A9A, Snohomish County,
Washington. universi ty of Washington, Office of Public
Archaeology. Reports in Highway Archaeology 6.
Thomson, Jack
1961 Preliminary Archaeological Survey of the Pilchuck River and South
Fork of the Sti11aguamish River. Washington Archaeologist, Vol. v.
No. 3.
E-20
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U.S. Environmental Protection Agency
1983 Portions of preliminary DEIS, Municipality of Metropolitan Seattle,
Sludge Management Plan, Region 10.
Whitfield, Wm.
1926 History of Snohomish County Washington, Vol. I. pioneer Historical
Publishing Co., Seattle.
E-21
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E-22
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Appendix F
Water Quality Data Pilchuck Site
-------
Appendix F
WATER QUALITY AND GROUNDWATER DATA
F-l
-------
P-2
-------
Table F-l. North Fork of the Stillaguamish River
Water Quality Data1
parameter
Specific
conductance
ph
temperature
color
turbidity
dissolved
oxygen
nitrate &
nitrite
ammoni a
ammoni a
total
phosphorus
total
phosphorus
units
umhos
units
degree C.
platinum
cobalt units
NTU
tng/1
mg/1
as N
mg/1
as N
mg/1
as NH4
mg/1
as P
mg/1
as ' J4
# o-f samples
59
59
59
56
56
59
59
59
9
59
9
statistic
mean
max i mum
minimum
maximum
max i mum
mean
max i mum
mean
max i mum
mini mum
mean
mean
max i mum
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 P04
mg/1
33
25
mean
mean
.02
24.2
non carbonate
hardness
dissoved
calcium
di ssol ved
magnesium
dissolved
sodium
di ssol ved
potassium
bicarbonate
carbonate
al kal ini ty
carbon
dioxide
dissolved
sul-fate
di ssol ved
chloride
•fecal
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
as CaC03
mg/1
mg/1
mg/1
coli-form2 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
max i mum
2.8
6.5
1.9
1.9
.6
26.7
0
21.8
2'. 3
4.3
2.0
57
120
Data -from USGS Water Resource Date 19771980
2 Data collected on August 12, 1977
F-3
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Table F-2. State of Washington Water Quality Standards
M
Extraord inary
A
Excellent
D
Good
P
•H - —
•H a a
8i~
gih
U. l§ S
ilSso
>i 9 (10t>100)
r*4 3
§ 14
M (10%>43)
•&3ioo
>< P (10%>200)
3"
M (10»>43)
2
•S a) 200
£ n (10t>400)
1 100
H (10t>200)
2
b «o
O O u Hi
« •n K
1 SS 3
> Q u id
7?
*» *~^ 10 id n.
Id ">*. 4* 10 c — *
""* IT P $ jP
1ft
s Q c f 1 1 n ***
>9.5 <110 t,23/fw5)
>? n < nn ^
>7.0< 110 t=fl/(T_4)
>8 0 <110 16
>8.0 <110 t=28/(T+7)
If)
>fi 0 <11Q
>b.O <110 (-,^,^2,
>6 5 <110 21
• ll° t=24/(T+9)
V**l
19
>5 0 <110
.• t= 16/T
11 >/
•8.5
6.5-8.5
(0.1)
7.0-8.5
(0.1)
6.5-8.5
(0.25)
7.0-8.5
(0.25)
6.5-8.5
(0.5)
7.0-8.5
(0.5)
1 j.
fr ||°
3 ° JK H 'I
is i * *
< , Shall be less than those which may
affect public health, the natural
aquatic environment, or the desir-
, , bility of the water for any usage.
< 3
< _ Shall be below those of public
health significance, or which may
cause acute or chronic toxic
, conditions to the aquatic biota,
or which may adversely affect any
water.
< ... Shall be below those which adversely
affect public health during the
exercise of characteristic usages, or
< 10 wni-cn tray cause acute or chronic
toxic conditions to the aquatic biota,
or which may adversely affect charac-
teristic water uses.
S
|
I
1
Aesthetic values shall not be uipairod
by the presence of materials or their
effects, excluding those of natural
origin, which offend the senses of
sight, smell, touch or taste.
Aesthetic values shall not be impaired
by the presence of materials or their
effects, excluding those of natural
origin, which offend the senses of
sight, snail, touch or taste.
Shall not be reduced by dissolved.
suspended, floating or submerged
matter not attributable to natural
causes, so as to affect water usage or
taint the flesh of edible species.
C
Fair
u) it 200 24
»« *ww >so *im
KS (iot>40o) ,:" 11U t=39/rmu
•5 >4 0 <1
H (e)
22
10 t»20/(T+2)
6.5-9.0
(0.5) 10
7.0-9.0
(0.5) <10
Shall be less than those which may
affect public health, the natural
acjuatic environment, or the desir-
ability of the water for any usage.
Aesthetic values shall not be impaired
by the presence of materials or their
effects, excluding those of natural
origin, which offend the senses of
sight, small, touch or taste.
Lake Class
(g)
(h)
(h)
VI
t
Shall be less than those which may
affect public health, the natural
aquatic environment, or the desir-
ability of the water for any usage.
Aesthetic values shall not be iirpaired
by the presence of materials or their
effects, excluding those of natural
origin, which offend the senses of
sight, smell, touch or taste.
lit) Shown in parentheses are the maximum percentages of samples allowed to exceed values indicated, when associated with any fecal source.
(b) Water tcnfjoraturc alia 11 not exceed values shown, duo in part to measurable (0.5T) increases resulting from huiwn activities, nor shall such temperature
increases, at any tiinc, exceed the (t) valua of the formula shown: t - permissive increase; T - water temperature due to all causes combined.
(c) Sluill IKJL L>! within tl«j raixjo uhown, with an indicod variation of loos than units shown in parentheses.
(d) 'lite natural turbidity conditions shall not bo exceeded by noro than the value shown.
(c) Dissolved oxyycn shall not exceed values shown, or 50 percent saturation, whichever is greater.
If) No measurable decrease fruit natural conditions.
(>|) No iivMsuroblc chorwjo fron natural conditions.
(10 Ui^:x)lvo
-------
Table F-3. Stream Water Quality Standards
Parameter
Fecal Coliform
Dissolved
Oxygen
Temperature
pH
Turbidity
Units
No./100 ml.
mg/1
NTU
Statistic
Median
10 percentile
Minimum
Maximum
Increase
Maximum
Minimum
Variation3
Increase
Increase or variation due to human activities
NOTE: < = Less than
Standards from WAG 173-201
SOURCE: Metro 1983d.
Water
Quality
Standard
<100
<200
8.0
18
0.3
8.5
6.5
0.5
F-5
-------
WATER-TABLE
AQUIFER
Monitoring Well
Water Level
Screened Interval
Bottom of Hole
ApproBimete Direction
"* of Graundwater Flow
Geologic Contact
~ I Daahed where inferred)
. Water-Table
FIGURE
Hydrogeologic Profile B - B'
c
SOUTH
300-
_ 200-
2
c
o
100-
c-
NORTH
WELL
2
WATER-TABLE
AQUIFER _
STILLAGUAMISH
RIVER
VASHONTILL
EXPLANATION
Monitoring Well
3Z Water Level
C Screened Interval
_L Bonom of Hole
Spring or Seep
Approximate Direction
of Groundwater Flow
Geologic Contact
(Daihed where inferred)
Water-Table
FIGURE fr-1
Hydrogeoiogic Profile C — C'
SOURCE: Metro 1982a.
F-6
-------
Table F-4. Pilchuck Tree Farm Spring Water Analysis
(Sampled March, May, June, July 1982)
Bluff Springs
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
Mean
(n = 7)
.019
1.46
.16
1.15
7.1
3.8
96
<.0001
<.024
<.007
<.0002
.026
<.029
<.006
113
4
74
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
MOTE: Yersinia was isolated from one sample.
MPN = Most Probable Number
< = Less than
SOURCE: Metro 1983d.
F-7
-------
Table F-5.
Preproject Groundwater Quality Data -
Pilchuck Tree Farm
NEE FMJI - IASEUK CMWDIAIEI SMM.IK
SIAIIM A - FUrilEM'S Kll
IDEE FMH - IASEUNE SDOMMMUt SAWUIS
SIAtlOl I - VIISWS' KU
SMFIE M1E Alt SAKPIE IKOtlC
CMVEITIOIAL CXEnlCALS
DRIKCIIG MIES
STANDARDS IEPAI
...
10.0 ig/l
...
—
—
—
—
1/20/82
15521 - DUrtlCAlE
.0031
.42
.0145
.54
1.5
1.5
50
.002t
.42
.022
.45
t.5
1.5
53
11/21/12
15512
(.Ml
.43
.027
•A
6.7
.1
53
12/11/12
15754
.Oil
.047
.021
.11
7.1
2.1
to
1/1/13
15751
.OOlt
.44
.055
1.1
1
3.4
to
CMVEITIOML OffKICALS
Aiioniui-1 1.9/11
litrate-H lig/ll
Phosphorus (ig/t)
Potassiui (19/1)
pH
lurbidlty (ITU)
Conductivity (fllhosl
MIKING HTEK
STANDARDS (EPA)
—
10.0 ig/l
—
—
—
...
...
SAKPIE
1/20/1?
15530
.0011
I.I
.42
1.05
4.2
2.4
148
tuni MIE MO SAIHE HMU:
V27/92
15544
nEtALS
Arsenic (19/1)
lariui lac/11
Ca£llui liq.'ll
M Chroilui lia/ll
| Cooper lig/ll
QO Iron (ig/l)
lead Ing/1)
ilercury (ig/ll
Stclel 119/11
Sele&tuc (19/11
Silver Ing/ll
line lij/1 1
0.05 ng/l
1.0 19/1
0.01 19/1
0.05 ij/1
—
—
0.05 n;/l
0.002 ig/l
...
0.01 >g/l
0.05 19/1
—
(.00!
.17
(.0001
.0011
.01
.12
.M2I
(.0002
.0014
(.0002
(.0001
.3
(.003
.15
(.OMI
.0015
.01
M
.0025
(.0002
.02
(.0002
(.000!
.05t
IA
NA
IA
IA
IA
IA
IA
IA
m
IA
IA
M
(.002
.06
.00017
(.001
.Mil
M
(.Ml
.OM3
.0011
(.Ml
(.OMI
.017
(.M2
.12
i
.M2B
.011
w
.0012
(.0002
.M32
(.001
.OMI
•
Arsenic (19/11
lanul llf/l)
Cidnui (19/11
Chro.lu. lig/ll
Copper Ug/ll
Iron lig/l)
lf)d li;/»
n>rcury (19/1!
Nickel lig/ll
Selenui 1.5/11
Silver li)/!)
line Itg/ll
0.05 if/I
1.0 ig/l
0.01 ig/l
0.05 ig/l
...
...
0.05 tg/l
0.002 19/1
...
0.01 ig/l
0.05 H/l
...
(.003
.11
(.0001
.0015
.02
.5
.0055
(.0042
.0?
(.OWI7
.0002
'.Wo
II/21/W
15511
(.001
3.2
.031
IA
t.t
.04
137
IA
IA
IA
•A
IA
IA
M
IA
M
M
12/11/82
15755
(.Ml
1.53
.021
1.35
5.7
1.2
145
(.002
.06
.00031
(.001
.0074
It
(.001
.0002
.0014
(.001
.021
I/3/B3
15760
.012
3.61
.026
1.52
7.5
1.5
133
(.002
.15
.0054
.013
.0011
.OW-3
ill '2 per 100 il
Fecal coition II per IW
ill '2 per 100 il
Fecal strept. (I per 100
ill
Saline!la (I per 100 ill —
Teriioia II per 109 ill
gall
PARASITES
MEMIC IOIICMTS
I.I. - Not detected
I.A. - lot analyzed
I'data it
<2
(2
5
(3
(3
(2
l.t.
I.I.
(2
(2
(2
IA
M
(2
(2
(2
IA
IA
'
(2
(2
(3
i
In
NA
IA
•tsulti ol tbe bacteria letting have been diuonel in a previous oeno. No cfcenc.l
•easureieiit eiceeded safe drinking niter itandardi. Fluctuations in nutrient content
are lot unusual ind pose no health concerns. Occanonal changes In trace elenent
concentrations nay also be eipected, particularly ihen the eleient il preient near
Ike lints ol detection.
Icttal cohlori H per 104
ill <2 per 100 il
Fecal cohfori II per 100
ll1 <: ptr 100 il
Fecal ttrtpt. II per IM
ill
Silionelli (I per IM ill •-•
VtniBii II per IM ill
VIMIS - lotil II per 100
till
PABASHES
ORCANIC TOIICAI1S
1.1. - Not detected
I.A. - lot analyied
Udata unavailable)
7?
<2
I.D.
1.1.
I
HA
IA
IA
M
114
, t
IA
IA
leults ol the bacteria testini, have been diumed it. a irevini «t«o. No cheiical
uaiurMtnt eiceeded tale drinking later ttandardt. Fluctuatiwt in lulritnt content
are not uiuiuil and pole no healtn concern!. Occationi! chaiites in trace eletent
coicentrationi lay alto be eipected, particularly nben tbt elemt is present near
tke lints ol detection.
-------
Table F-5. Cont'd.
mi FARIt - BASELINE GROIJNWATER SAKPL1NG
STATION C - HITSCHER'S NELL
TREE PARK - BASELINE 6ROUNDHATER SAMPLING
STATION D - L1NDAL/ESPERSON HELL
vo
CONVENTIONAL CHEdlCALS
Aaaoniui-N lag/11
Nitrale-N ias.'ll
Phosphorus lig/lI
Potasses Icg/ll
P«
Turbidity !NTU)
Conductivity (r.shosl
NETALS
DRINKING HATER
STANDARDS (EPA)
10.0 ag/1
Arsenic (tg/ll
Bariui !i;/l)
Cadnue (15/1)
Chrouufi (ig/l)
Copper (rg/1)
Ircr, l,i;/l!
Lead leg'/ll
Rtrcury Is:/!!
Nickel Icq.'ll
SeleniuB li;/l)
Silver (1-5/11
line fftc/l)
0.05 ig/1
1.0 tg/1
0.0! eg/1
0.05 tg/1
—
—
0.05 eg/!
0.002 ao/1
0.0! ig/1
0.05 eg/!
—
SAIfPLE DATE AND SAItPLE NUMBER:
9/20/82 9/27/82
•5531 15545
IColifora only)
.0038
1.96
.005?
.37
4.2
5.7
194
<.003
.21
(.0001
(.001
.05
(.03
.024
(.0002
.02
.0004
(.0001
.034
Total colifora II per 100
ill •:: :er 100 nl
Fecal colliers !l per ay also be expected, particularly «hen the eleient is present nea
the liiits of 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 mg/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.
F-10
-------
Appendix G
40 CFR Part 257 Criteria for
Classification of Solid Waste
Disposal Facilities and Practices
-------
Appendix G
EPA CRITERIA FOR CLASSIFICATION OF SOLID WASTE
DISPOSAL FACILITIES AND PRACTICES (40 CFR PART 257)
G-l
-------
G-2
-------
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)
G-3
-------
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. 20460.
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. 20460.
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 6944(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. State, 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
State plans which satisfy the minimum
requirements of Section 4003.
The State solid 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 x
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 hearth 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 d*umps 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 State
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 States * * *."
B. Section 1008(o)(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 are 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
does 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
G-4
-------
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 40S(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
structure 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
1008(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 that
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 solid
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, implementation
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 that 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
of solid waste disposal activities. EPA
examined 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
lolid 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(1978)) 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 1002fb)(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
, 6. The criteria do not apply to source,
special nuclear, or byproduct material
as defined by the Atomic Energy Act of
1954, as amended (68 Stat 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 discharged.
The principal purpose of this provision
is to assure that waters of the United
States (the jurisdicn'onal 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
waste? 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 activityxregulated by
UICP) could also fall within 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 (Sectiont257Jj
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 in 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 5 257.3-6.
D. Floodplains (Section 257.3-1 J
Disposal of solid waste in floodplaina
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
sought 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 the
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 is 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 floodplaina. 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.
£1 Endangered and Threatened Species
(Section 257J-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 was
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.
£PA 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 cnuse 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 of 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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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 Till 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.) Non-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 States 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, as 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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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 ground water
.needed or used for human consumption.
(1) Approach to Ground-watee
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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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
treatmenr-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 (NIPDWR) 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 leachate 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
leachate which can be injurious to
health.
However. EPA has decided not to
include the 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 of fish 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 "endungerment" approach
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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, qr 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 impaired, 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 aquifer does 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 (i.e.
within the facility).
However, the proposed criteria
recognized that monitoring and control
of leachate within the property
boundary would generally be necessary
in order to assure that 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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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 any 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
that 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 leachate. 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 water
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 State 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 corrrmenters
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 within 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/I 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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scq.). This provision of the Safe Drinking
Water Act is administered through
regulations 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
, 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 rulemaking 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. Castle, 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 had 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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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, two 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 aP6.5 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 Br-microglobulin. which is the earliest
discernible laboratory evidence of organ
damage. Although mild or moderate
increases in excretion of Bi-
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 metalincreases
with age. Further, the autopsy data
indicate that for the general United
States 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 proteinuria. 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
8 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
ingestion level is about 39 micrograms
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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 also" 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/day 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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53452 Federal Register / Vol. 44. No. 179 / Thursday. September 13. 1979 / Rules and Regulations
control provision. This modification
would allow such.wastes as food
processing residuals to be landspread
without unnecessary pH control
measures.
~ (c) Maximum Cumulative Loadings of
Cadmiunf.—Comments received on the
cumulative cadmium application limits,
soil pH. and soil catfon 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 that 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
leafy vegetables to those in other
classes. The ratios were then applied 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 CECs
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
show 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 are 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 rates on soils with a natural
pH that is very highly acidic (including
prohibition on landspreading on soils
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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 is
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 soil analysis 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 test 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 of "accumulator" 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
"be 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 ths public health.
EPA recognizes that not 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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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 commenters
stated that this approach would be very
difficult to implement because of
problems in establishing an effective
system to monitor and control
agricultural 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 jpneral 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'a 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
soil 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 com, 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 property 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
ongoing 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
substances. 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 sources
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 weigh!) for animal feeds and 1.5
mg/kg (fat basis) for milk. The standard
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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
PCB level in the waste material is 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
to-4and 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
pump ings 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.
Sewage sludge applied to the land.
surface or incorporated into the soil
must be treated by a Process to
Significantly Reduce-Pathogens. Aerobic
digestioa 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 orburial 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, and
grazing of animals whose products are
consumed by humans must be prevented
for at least one month.
Like 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 to 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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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 generation and
surface and ground-water
contamination: and (d) it improves the
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 to 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 Sludge 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 targe 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 pumpings 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 play 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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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 evidence
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 to
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 fmafair 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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^^^^^^^^^^^^^^^^^—^^^^^^^^^^^^——^^^—^^^^^^—^^^—^^^^^—.—^-^—-—^—i^^^^—_^^^^_^^^__——^—fl—^™-————^^B™™*™™™™™™^^^^^^^™™™^™^^^™^™™™™™^™™^™™^^^
from emergency clean-up operations and
ordnance.) Second, air emissions caused
by solid waste disposal activities shall
not violate applicable requirements
' developed for State 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 leachale
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 burn.
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 State
SIP.
In requiring compliance with the SIP,
EPA is seeking to coordinate the criteria
with the Clean Air Act, as mandated in
Section 1006 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 to 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 commenters said that
the proposed criteria "federalized" State
and local air regulations. EPA is not
federating 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 commenters requested
clarification regarding the impact of the
criteria on the use of pit or trench
incinerators. Emission factors (i.e.,
particulates) 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
commenters noted that since OSHA air
quality standards are based on
workplace exposure and riot 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 (§ 257.3-8) since many
of the dangers of open burning relate
directly to 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 safety criteria have been
revised to reference the air criteria.
K. Safely (Sect/on 257.3-8)
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 to 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
solid waste disposal that present a
public health hazard. Even if such a set
of gases could be identified it is difficult
• to determine, on the basis of data
currently available to EPA, what levels
of such gases may be tolerated without
a substantial risk to 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.
Commenters 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
commenters 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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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. Cases at or below the LEL at
the property boundary will necessarily
become somewhat diffused before
passing into a structure beyond the
property 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 several 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 df 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
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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 defining 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
stated 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.
Commenters 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
such control.
During normal operating hours, proper
management controls can minimize
safety hazards. For example, potential
harm 1o 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
solid 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 on this
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'sjjpsjtipn.
Dated: September 10.197S.
Douglas M. Coslle,
Administrator.
Title 40 CFR is amended by adding a
new Part 257 to read as follows:
PART 257—CRITERIA FOR
CLASSIFICATION OF SOUD WASTE
DISPOSAL FACILITIES AND
PRACTICES
Sec.
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.
257.3-8 Safety.
257.4 Effective dale.
Authority: Sec.'l008{a)(3). and sec. 4004(a).
Pub. L 94-580. 90 Stat. 2803 and 2815 (42
U.S.C. 6907(a)(3). 6944); sec. 405(d). Pub. L.
95-217, 91 Slat. 1591.1608 (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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(2) Practices failing to satisfy these
criteria .constitute open 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'are 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 (68 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 Floodplains.
(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.
G-27
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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 hydrogeological
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 of alternative
drinking water supplies:
(6) 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:
(!) "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.
§ 257.3-5 Application to land used for the
production of food-chain crops (Interim
final).
(o) 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:
Sol canon ncfwng* capacity (maq/
100g)
TifiM pcnod
Annual CD
phCftDOfl T
(kg/ha)
Present 10 June 30. 19M
Jury 1. 1984 10 OK. 31. 1988
Beginning Jan. 1. 1987
2.0
1-2S
0.5
(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 cumuuuvn tppucatton (kg/ha)
Sol canon Background tod pH Background tot pH
tichang* capacity <8 5 > (.5
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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 method. ("Methods of
Soil Analysis, Agronomy Monograph
No. 9," C.A. Black, ed., American
Society of Agronomy, Madison,
Wisconsin, pp. 914r-926,1965.) -
§257.3-5 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 gr.own 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 0.
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.J.
(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
G-29
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53464 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 fire 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.
§ 257.4 Effective date.
These criteria become effective
October 15.1979,
Appendix I
The maximum contaminant levels
promulgated herein are for use in determining
whether solid waste disposal activities
comply with the ground-water criteria
(§ 257.3-4). Analytical methods for 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
maximum levels of inorganic chemicals other
than fluoride:
Conumnam
Level (mikgrams per
"fTVV
Hitr+tm (re M)
^ilweW
or*
1
0010
nn*.
00$
nno?
, , 10
001
0 05
The maximum contaminant levels for
fluoride are:
Temperature1
degrees
Fuvennei!
53.7 end below
53-8 10 583
58 4 10 63.8
63 9 to 70 6
70 7 lo 79.2 _
79.3 10 90.5
Degrees
Celsius
— 12 and below __
— 12.1 10 146
14 7 10 176
_ 17710214
-_ 21 S 10 26 2 _
.._ 26J 10 32 5
Lev*
(mrifcgrams
per Her)
2.4
22
2.0
18
t.«
1.4
' Annual average of the mannum duly •• temperature.
2. Maximum contaminant levels for
organic chemicals. The following are the
maximum contaminant levels for organic
chemicals: :
Level
(milligrams
(a) Chlorinated hydrocarbons: p*f "*'
EndVm (1.2.3.4.10.iO-M«.acNoro-6.7-epo»y.
1.4.4a.5.e.7.8.8e-octanvaro-i.4.endo, endo-
5.8-dimetnano napninaiene) 0.0002
Lindane (1,2.3.4.5.6-HeiacnKxocyclone«ane.
gamma oomer— _ 0004
MethoiycNor (1,1.1-Trichloro.2.2-bi> (p-meih-
oiypnenyl) ethane) 0.1
Toiapnene (C,.H»CI,-Tecnnical chionnaied
camphene. 67 to 69 percent cnkxine) 0005
(b) Chtoropheno»ys
2.4-O (2.4-Dienioropneno«y-aeelic acid) 0 1
2.4.5-TP Sdve» I2.4.5-
Tricnioropnenoivpropionic acid) 001
3. Maximum microbiological contaminant
Irvels. The maximum contaminant level for
coliform bacteria from any one well is as
follows:
(a) using the membrane filter technique:
(1) Four coliform bacteria per 100 milliliten
If one sample is taken, or
(2) Four coliform bacteria per 100 millilitera
In more than one sample of all the samples
analyzed in one month.
(b) Using the five tube most probable
number procedure, (the fermentation tube
method) in accordance with the analytical
recommendations set forth in "Standard
. Methods for Examination of Water and
Waste Water". American Public Health
Association. 13th Ed. pp. 662-686. and using a
Standard sample, each portion being one fifth
of the sample:
(1) If the standard portion is 10 milliliten.
coliform in any five consecutive samples
from a well shall not be present In three or
more of the 25 portions, or
(2) If the standard portion is 100 milliliters.
coliform in any Five consecutive samples
from a well shall not be present in five
portions in any of five samples or in more
than fifteen of the 25 portions.
4. Maximum contaminant levels for
radium-226. radium-228. and gross alpha
panicle radioactivity. The following are the
maximum contaminant levels for radium-226.
radium-228. and gross alpha particle
radioactivity:
(a) Combined radium-226 and radium-228—
5 pCi/1:
(b) Gross alpha particle activity (including
radium-226 but excluding radon and
uranium)—15 pCi/1.
Appendix II
A. Processes to Significantly Reduce
Pathogens
Aerobic digestion: The process is
conducted by agitating sludge with air or
oxygen to maintain aerobic conditions at
residence times ranging from 60 days at 15* C
to 40 days at 20* C. with a volatile solids
reduction of at least 38 percent.
Air Drying: Liquid sludge is allowed to
drain and/or dry on under-drained sand
beds, or paved or unpaved basins in which
the sludge is at a depth of nine inches. A
minimum of three months is needed, two
months of which temperatures average on a
daily basis above 0* C.
Anaerobic digestion: The process is
conducted in the absence of air at residence
times ranging from 60 days al 20' C to 15
days al 35* to 55* C. with a volatile solids
reduction of al least 38 percent.
Composting: Using the within-vessel, static
aerated pile or windrow composting methods.
the solid waste Is maintained at minimum
operating conditions of 40' C for 5 days. For
four hours during this period the temperature
exceeds 55' C.
Lime Stabilization: Sufficient lime is added
to produce a pH of 12 after 2 hours of contact.
Other methods: Olher methods or operating
conditions may be acceptable if pathogens
and vector attraction of the waste (volatile
solids) are reduced lo an extent equivalent to
the reduction achieved by any of the wbove
methods.
E. Pracoiset to Further Reduce Pathogens
Composting: Using the within-vessel
composting method, the solid wasle is
maintained at operating conditions of 55* C
or greater for three day*. Using the static
aerated pile composting method, the solid
waste is maintained at operating conditions
of 55* C or greater for three days. Using the
windrow composting method, the solid waste
attains a temperature .of 55* C or greater for
al least 15 days during the composting period
Also, during the high temperature period,
there will be a minimum of five turning* of
the windrow.
Heat dryng: Dewalered sludge cake I*
dried by direct or indirect contact with hot
gases, and moisture content is reduced to 10
percent or lower. Sludge particles reach
temperatures well in excess of 60* C or the
wet bulb temperature of the gas stream in
contact with the sludge at the point where il
leaves the dryer is in excess of 80* C.
Heat treatment: Liquid sludge is healed to
temperatures of 180* C for 30 minutes.
Thermophilic Aerobic Digestion: Liquid
sludge Is agitated with air or oxygen to
maintain aerobic conditions at residence
times of 10 days al 55-60* C with a volatile
solids reduction of at least 38 percent
Other methods: Other methods or operating
conditions may be acceptable if pathogens
and vector attraction of the waste (volatile
solids) are reduced to an extent equivalent to
the reduction achieved by any of the above
methods.
Any of the processes listed below, if added
to the processes described in Section A
above, further reduce pathogens. Because the
processes listed below, on their own. do not
reduce the attraction of disease vectors..they
are only add-on in nature.
Beta ray irradiation: Sludge is irradiated
with beta rays from an accelerator at dosages
of al least 1.0 megarad at room temperature
(ca. 20* C).
Gamma ray irradiation: Sludge is
Irradiated with gamma rays from certain
isotopes, such as "Cobalt and '"Cesium, at
dosages of at least 1.0 megarad at room
temperature (ca. 20* C).
Pasteurization: Sludge is maintained for at
least 30 minutes al a minimum temperature of
70* C
Other methods: Other methods or operating
conditions may be acceptable if pathogens
are reduced to an extent equivalent to the
reduction achieved by any of the above add-
on methods.
FR Doc 79-as3» Filed a-l'-TO US srn|
BILLING CODE 656O-01-U
G-30
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Appendix H
Legal, Policy, and Institutional
Considerations
-------
Appendix H
FEDERAL REQUIREMENTS RELEVANT TO
SLUDGE MANAGEMENT AND DISPOSAL
H-l
-------
H-2
-------
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.
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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 seg.). The Clean Air Act
(CAA) sets the basicframework 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.
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Marine Protection, Research and Sanctuaries Act (33 USC
1401 et seq.). Under this law, ocean dumping of sewage sludge
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.). SMCRA sets forth the requirements and general
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.
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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.
Various state and areawide clearinghouses facilitate the
notification, review and dissemination of project plans and
EISs, as specified by OMB Circular A-95.
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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
policies and procedures for protecting endangered 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.
Cultural Resource Protection. A number of federal laws and
regulations have been promulgated to protect the nation's
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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.
Protection of Agricultural Lands. On September 8, 1978,
EPA issued its policy to protect environmentally 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.
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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 to 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 (WAG 173-301). Under this law,
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.
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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
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.
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Forest Practices Act (RCW 76.09). This Act and the associ-
ated Forest Practices Regulations(WAC 222-08 et seq.) establish
minimum standards for forest practices in Washington. Silvi-
cultural application of wastewater sludge will need to comply
with relevant forest practices standards and administrative
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.
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Appendix I
Advisory Committee Statements
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Appendix I
ADVISORY COMMITTEE STATEMENTS
201 CITIZENS' ADVISORY COMMITTEE
SLUDGE PROJECT ADVISORY COMMITTEE
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May 31, 1983
TOs Environmental Protection Agency
FROM: 201 Citizens' Advisory Committee on Sludge
SUBJECT: Committee Recommendation on Sludge Management Plan
SLUDGE 201 CITIZEN'S SLUDGE ADVISORY COMMITTEE FINAL
COMMENTS ON:
A. DRAFT SLUDGE MANAGEMENT PLAN
The Advisory Committee, in principle, supports the contents
and format of the draft plan. However, there are ten areas
that need significant revisions in the opinion of the Com-
mittee. The order in which these are raised below is not
meant as an indication of priority.
1. We recommend Metro vigorously explore opportunities
for converting sludge to useful energy. Incineration,
methane generation and capture, co-incineration with
municipal solid waste, and enhancement of the tree
growth on "energy plantations" are promising tech-
nologies which should be considered in this light.
Specifically, we recommend that a demonstration
project (similar to those which demonstrate land
application at Pilchuck Tree Farm, Pack Forest, and
WIDCO) for energy production be incorporated in the
Recommended Plan.
2. We recommend that Metro conduct on-going research and
monitoring to:
a. minimize or eliminate the heavy metals and toxic
organic chemicals from digested sludge;
b. assure that land application of sludge does not
compromist the health and safety of humans and
animals through infiltration of heavy metals of
toxic organic chemicals to their water or food;
c. maintain advantageous standards to accomplish the
goal of a and b as technology improves.
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Committee Recommendation on
Sludge Management Plan
May 31, 1983
Page 2
3. We recommend that Metro conduct additional research to
confirm or deny the existence of potentially harmful
micro-organisms in composted sludge. Our particular
concern is for the health of workers at sludge com-
posting facilities and persons who apply compose on a
regular basis. Prevautions to decrease human contact
with micro-organisms should be incorporated in
existing composting procedures, until further research
on health effects is forthcoming.
4. We recommend that Metro unequivocally state in the
Sludge Management Plant that ocean disposal will not
be implemented even if it should become a legal
disposal method within the planning period (20 years).
Although this is the least costly alternative, the
adverse environmental effects should prohibit further
consideration of this option.
5. We recommend that Metro's public participation program
emphasize extensive public education (in addition to
the recommended committees, hearings, etc.) beginning
now and extending throughout project implementation.
6. We recommend that the "Rate Impact Analysis" in the
Recommended Plan (Chapter 5) incorporate a statement
regarding the desirability of lower rates for persons
on fixed incomes.
7. We recommend that the types of monitoring which would
accompany each of the recommended sludge utilization
methods be enumerated in the Recommended Plan
(Chapter 5).
8. We recommend that site selection criteria be explained
in the draft plan. The statement on page 66 that site
selection will follow the DOE's Best Management
Practices skirts this important issue that will affect
public acceptance of various alternatives.
9. We recommend that investigation of regional sludge
management be a primary goal of the Recommended Plan.
10. We recommend taht the plan recognize that compose may
be used in non-urban as well as urban areas, and
therefore the potential impacts of compost on wildlife
and water quality should be evaluated.
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Committee Recommendation on
Sludge Management Plan
May 31, 1983
Page 3
We commend the Metro staff for their responsiveness to the
Advisory Committee's comments and suggestions throughout the
past year during the development of the draft plan.
In conclusion, the Advisory Committee reaffirms its earlier
recommendation that Metro pursue composting, silviculture ap-
plication, and soil improvement as the best methods at present
for utilizing the sludge resource. We are most hopeful that the
Metro Council's decision on this plan and future site selection
decisions will be based on technical, economic, and environ-
mental considerations.
B. COST EFFECTIVENESS ANALYSIS OF SYSTEMWIDE SLUDGE MANAGEMENT
ALTERNATIVES (June 1982)
Metro staff has recommended disposal of digested sludge by
three forms of land application: silviculture, soil im-
provement, and composting. The Citizens' Committee has
considered the logic and recommendations of Metro staff and
has general concern regarding the following issues:
1. The long term effects of heavy metals have not been
adequately addressed. While Metro and other agencies
have performed extensive research in recent years on
the effects of land application of sludge (and the
movement of heavy metals in the soil) , we feel the
research results lack significant long term obser-
vation and analysis. Effects of buildup of heavy
metals over the life of the 20-year management plan
need more consideration.
We recommend that Metro staff provide additional
information/documentation regarding:
a. potential for pretreatment to remove heavy metals
from the treatment stream
b. additional treatment at the plant(s) to remove
heavy metals prior to digestion of sludge or dis-
charge of effluent
c. any long term monitoring programs demonstrating
movement or accumulation of heavy metals in
soils, groundwater, or surface runoff.
2. The Sludge Advisory Committee endorses the concept of
sludge utilization as a resource. Sludge can be used
either as a soil amendment or as an energy source.
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Committee Recommendation on
Sludge Management Plan
May 31, 1983
Page 4
The three options currently under consideration are
all related to soil amending. We feel that the energy
options should be reconsidered to make the best and
most complete use of the sludge and to give the
program needed flexibility.
In conjunction with the options of using sludge as a
soil amendment comes the consideration of finding
adequate, suitable land. Sometime this may mean going
outside of King County. The Committee feels that
every effort should be made to identify other areas
that may accept Metro's sludge as a soil amendment.
The sludge could be transported by rail or barge to
existing privately owned lands or to lands purchased
by Metro.
Public acceptance of proposed sludge disposal methods
has not been good. Metro has conducted four public
meetings to present proposed programs. Of the four,
three meetings were held in communities proposed to
directly receive land application of digested sludge.
In Orting and Belfair, citizen reaction was definitely
opposed to the proposed program. Citizens have a
right to a meaningful voice in determining govern-
mental activities in their communities. Therefore,
more emphasis should be given to public education of
program advantages and disadvantages - as well as
options - than on "selling" or "marketing" a
particular program to a particular community.
We feel the three proposed disposal methods really
provide only one option, land application. We believe
the most cost effective high-technology option should
be considered for further evaluation. We recognize
that strict dollars and cents evaluation may not
render any high-tech options cost effective, when
compared to land application options, but feel that
the ability of Metro to absolutely control a high-tech
disposal method is a significant advantage. Inclusion
of a high-tech option provides significant added
flexibility in the sludge disposal process.
The Cost-Effectiveness Analysis considers most high-
tech options unreliable while characterizing land
applications as reliable. We question the reliability
of the land application option for the reasons stated
above.
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Committee Recommendation on
Sludge Management Plan
May 31, 1983
Page 5
C. COMPOSTING AS A SLUDGE MANAGEMENT ALTERNATIVE(December 1982)
The use of composted sludge as a soil amendment product
should be pursued as part of a total program of sludge
disposal. The Metro process of modified static pile
composting with 40% solids appears to be the most suitable.
As the processing of composted material becomes more of a
practical reality, Metro should continue to investigate new
and innovative techniques. Protection from adverse weather
conditions, containment of objectionable odors and
reduction of pathogens during processing to acceptable
level should be required. Consideration should also be
given to aerated windrow composting since over twice as
much sludge can be processed with this method than the
modified static pile 40% method. Perhaps more investi-
gation could resolve the problems of high capital and
energy costs in the windrow process. Although the methods
now employed seem to be adequate for pilot processes, they
may not be adequate for a significant year-round
production. The study of methods and equipment in use in
other locations, nationally and internationally, should
continue.
Consumers should be given adequate warning to use Metro's
compost only on non-food chain crops because of the heavy
metal content. Studies should continue to examine the
possibility that pathogenic fungi such as Aspergillus
fumigatus and bacteria such as Micropolyspora facni and
Thermoactinomyces vulgaris may be present during the
composting procedure. The organisms could pose a hazard to
those persons processing and spreading the finished
compost.
To provide for the development of adequate sources of
bulking materials used in the composting process an
agreement could be negotiated with timber companies
receiving sludge for silvicultural applications. This
would ensure an alternate source of sawdust or woodchips.
Also newspapers or other biodegradable solid waste
materials should be investigated as atlernate bulking
agents. This would provide additional sources if sawdust
or woodchips become unavailable.
A promotional program using compost should prove to be an
effective means for gaining acceptance of any recycled
sludge product. Composted sludge should be made available
for use by the public sector. It would become a desirable
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Committee Recommendation on
Sludge Management Plan
May 31, 1983
Page 6
and highly visible promotional aid in any community through
applications on open spaces (parks, vacant lots, unused
rights-of-way, etc.).
D. SILVICULTURE AS A SLUDGE MANAGEMENT ALTERNATIVE (December 1982)
The Citizens' Committee has reviewed the option of using
sludge to accelerate tree growth. This alternative has the
potential to benefit forest lands, to utilize the nutrient
content of sludge, and to solve Metro's sludge disposal
problem. However, the Committee has three areas of concern
with regard to silvicultural applications for sludge utili-
zation: potential environmental problems and the need for
monitoring, availability of utilization sites, and public
acceptance of this activity.
Potential Environmental Problems and the Need for Monitoring
The misuse of sludge either through negligence or lack of
knowledge can lead to adverse environmental effects. Since
much of the research on sludge application to northwest
forest areas have been done only in the last decade, long
term environmental effects have not had sufficient time to
become apparent; continuing research is needed.
Sites with soil characteristics that are appropriate for
adsorbing metals and preventing the leaching of nutrients
into groundwater are advisable. Extensive groundwater
monitoring is necessary to verify the containment of
nutrients and metals to protect drinking water sources and
surface streams.
The long residence time of metals in the soil may lead to
their continuous uptake by the surrounding vegetation.
Vegetative accumulation may adversely affect the forest
wildlife community and may be accompanied by bioaccumu-
lation in forest products, such as mushrooms, berries and
game which are used for human consumption. Effects on
wildlife should be included in the continuing environmental
research.
To summarize, careful selction of site, extensive moni-
toring, and continued research on the long term environ-
mental effects is needed.
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Committee Recommendation on
Sludge Management Plan
May 31, 1983
Page 7
Site Availability
The viability of the silvicultural alternative depends upon
the availability of sites which meet highly selective
criteria. In the Metro service area, there appears to be a
shortage of sites that will meet these selective criteria.
The Committee feels that Metro should take positive action
toward developing interagency cooperation on sludge utili-
zation to secure sites beyond Metro's service area. Such
cooperation could be approached at three levels: minimal
cooperation (permitting), a moderate level, or full scale
agreements.
At a minimal level, Metro would be granted a health depart-
ment permit for sludge application on forestland.
At an intermediate level of cooperation, other communities
would actively participate in seeking sites for sludge
utilization because they would perceive increased forest
growth and soil improvement as "free" benefits for agreeing
to the use of sites in their jurisdiction.
With full scale interagency cooperation, we would see joint
planning for the utilization of sludge which is generated
by Metro and other communities in the region and the
sharing of implementation and monitoring costs.
The committee encourages Metro staff and Metro Council to
view interagency cooperation as a feasible and desirable
approach for securing forest utilization sites.
Public Acceptance
The Committee feels that Metro should employ honest, edu-
cational efforts to dispel the public's prejudices
regarding sludge. This is especially important in the com-
munities immediately surrounding the sludge application
sites. The public's cooperation and involvement should be
sought early in the planning process. Every effort should
be made to assure people that every possible protection of
health and safety will be implemented.
Conclusion
The Committee does feel that application of sludge for
improved tree growth, if properly controlled and monitored,
is beneficial to Metro's service area, the recipient com-
munity, and the economy of the region. The ultimate goal
1-9
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Committee Recommendation on
Sludge Management Plan
May 31, 1983
Page 8
should be to make sludge a resource that is advantageous to
all parties.
E. SOIL RECLAMATION AS A SLUDGE MANAGEMENT ALTERNATIVE
(December 1982)
The use of digested sludge for soil reclamation can be
reliable, flexible and cost effective when applied to ap-
propriate open spaces such as: power line rights-of-way,
freeway rights-of-way, gravel pits, strip mines and recre-
ation areas in need of revegetation. Slow nitrogen release
over a long period of time is ideal for starting cover
crops.
Projects such as the strip mine reclamation by WIDCO should
be promoted and utilized to their maximum capacity based
upon cost effectiveness. Emphasis should be placed on
developing project sites where the material can be used
effectively.
A possible adverse impact of this alternative is the con-
tamination of surface and ground water by nitrates, heavy
metals and pathogens. Al precautions must be taken to
avoid such contamination.
Due to the success of past soil reclamation projects,
public acceptance can be anticipated. Every means should
be employed to ensure adequate public involvement. Having
a lush green growth where nothing could grow before is the
reward for the use of sludge in soil reclamation.
TE:elb
B7/CR/1
1-10
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MEMORANDUM May 19, 1983
TO: Metro of Seattle and Pilchuck Tree Farm
FROM: Sludge Project Citizens' Advisory Committee
SUBJECT: Final Recommendation of the Committee on the
Proposed Phase I Sludge Application Project.
On December 2, 1981, this committee met for the first time. Some
of its members were initially invited by Duane Weston of the Pilchuck
Tree Farm to serve and other individuals requested membership. The
committee has been concerned with two overriding motives: concern
for the public health, and the preservation of environmental integrity-
Economic incentives, as they apply to either Pilchuck Tree Farm or
Metro, have played little or no part in the committee's deliberations.
We have trusted that these incentives would be adequately addressed by
the two principals involved in the project.
In the eighteen months of its existence, the committee has studied
exhaustively the proposed Pilchuck Tree Farm Demonstration Sludge
Application, Phase I. We evolved a list of seventeen "concerns" in
response to the various aspects of the project. These concerns were
addressed with the aid of field trips to various laboratories and test
sites, and extensive explanations from the Metro staff. Answers to
these concerns were considered individually, to the satisfaction of
this committee. During that time, expert documentation from outside
sources was obtained*. The committee also listened at length to a
group of local residents who are adamantly opposed to the project under
any circumstances.
The committee submits the following findings:
1) That sewage sludge can be a valuable and recyclable product of
the Metro sewage treatment"process.
2) That prelimary research on the silvicultural application of sludge,
has been accomplished at Pack Forest through the University of
Washington. This research has produced positive -information
regarding tree growth resulting from such application. It has
also produced much data about health and ecological impacts.
University of Washington, University of Texas, Cornell University
(Toxic Chemical Laboratory), University of Wisconsin (Dept. of
Horticulture), USDA Research Laboratory in Maryland.
1-11
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Final Committee Recommendation Page 2
3) That the proposed demonstration project near Arlington follows
logically upon the previous research at Pack Forest.
We therefore recommend that Phase I of the Sludge Application Project
go forward, and wish to append three suggestions to that recommendation:
1) Of the utmost importance to this committee's decisions and recommen-
dations was the verbal commitment by Duane Weston of the Pilchuck
Tree Farm to accept our positive or negative recommendation on the
Phase I Sludge Application Project.
Since much of the testing, monitoring, and research results of
Phase I will not be available until a later date, we ask that this
same commitment between the Pilchuck Tree Farm and the Sludge
Advisory Committee apply to the inception of Phase II of the Sludge
Application Project. Eventual full acceptance of this project by
the community may depend largely upon this committee's continued
part ici pation.
2) That improvement of the pre-treatment process be pursued by all
possible means (including stricter regulatory enforcement) so that
fewer contaminants are introduced into the environment in the course
of further sludge applications.
3) That further research on si 1vicultural sludge application be
designed and carried out in a more site-specific way.
As this committee has functioned strictly as a volunteer group of lay
persons, we feel that we cannot be expected to accept any legal
responsibility for impacts resulting from this project.
The committee looks forward to serving further in a monitoring capacity
and appreciates the responsive attitude which has been the rule from
both Metro and Pilchuck Tree Farm.
cc: Earl Rice
Duane Weston
Kathy Davidson
All committee members
1-12
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Appendix J
Assessment of Land Values
Pilchuck Site
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Appendix J
ASSESSMENT OF LAND VALUE
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Snohomish County Assessor
ROBERT A. SHAW,
RICHARD L McANINCH. Chief Deputy
Third Floor, Administration Building • Everett, Washington 98201 • Phone: (206) 259-9433
September 8, 1982
Mr. Earl H. Rice
Pacific Denkmann Company
1624 300th St. N.W.
Stanwood, Washington 98292
Dear Mr. Bice:
This letter is in response to your recent questions
concerning the impact of a proposed project for fertilizing
trees with sludge on adjoining property values and the re-
valuation cycle for that area.
The Snohomish County Assessor's Office is on a systematic
three year revaluation cycle that results in every parcel of
property in this county being appraised for tax purposes every
third year. This program has been in effect for more than nine
years and is a part of a plan on file with the Washington State
Department of Revenue. Your project will not affect this syste-
matic and preplanned program and we will not make any special
reassessment efforts in your area. According to the normal re-
valuation cycle, all the property in the Arlington School
District will be reappraised as of January 1, 1983 effective
for the 1984 tax.
We have reviewed the project plans as presented by your
company and, based upon the information available, do not
anticipate it affecting adjoining property values. Property
values are subject to many influences and will most certainly
change with time, but we do not believe the proposed fertilizat-
ion program will be a significant factor.
J-l
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(cont)
Please let me know if we can be of further assistance
in this matter.
RM:dj
Sincerely*
Richard McAninch
Chief Deputy Assessor
J-2
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Appendix K
Distribution List
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Appendix K
DISTRIBUTION LIST
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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
K-l
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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 Wilson
Cathy Frojen
Kay Crabtree
Dale Duskin
Jeffrey Hoi beck
Herbert Hower
Mark Lucianna, MD
K-2
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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 Nickerson
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. Linda!
Mr. & Mrs. Schulberg
Don Graham
Bob Burk
Mr. & Mrs. King
Ron Sessa
Glen Kieso
Steve Potter
Lewis Kinney
Hazel McDougall
Joan Witscher
Wannetta Wilkes
Dick Myers
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 Beals
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
John Edwards
Jim Puckett
Charles Hodge
Bernard Koenig
Joseph E. Simmons
Artur Kos
Mr. & Mrs. Vanderberg
Rex Peckham
Dennis Somerville
Maxine Janise
Mrs. Marc Hayes
Virginia Hayes
Ruth Pfeiffer
Shari Thompson
Lisa Creton
K-3
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Merolyn Dahl
David L. Thomas
John Lala, Jr.
Thelma Hayes
Betsy R. Bolgen
DeWain C. Meagele
P- L. Binstock
Lorna Havens
Compost Systems Co.
Richard I. Dick
Jack O'Brien
Jerry Bergsman
Carol A. Howe
Briscoe Maphis
Mr. & Mrs. Toney
Dave Clark
Dick Zemp
Eunice Bolie
Delia Ewig
William Sopper
Beth Davis
Ruth Van Dyke
Patricia Gibbons
Harry Anderson
University of Oregon Library
John & Ruth hoelzel
Ida Maye Kapustik
Jeanne Daily
Algird & Agnes Paulick
Jack & Jean Gummer
David & Joan Cox
Suzanne Mull in
K-4
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