EPA 910/9-84-119
&EPA
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
June, 1984
Water
EPA-10-OR-Eugene/Springfield-Lane-WWTW-84
Environmental Final
Impact Statement
Metropolitan Wastewater
Management Commission
Sludge Management Plan
Eugene-Springfield, Oregon
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
^ 1200 SIXTH AVENUE
g SEATTLE .WASHINGTON 98101
REPLY TO ._ ..0
ATTN OF: M/S 443
June 15, 1984
TO: All Interested Agencies, Public Groups and Citizens
Enclosed for your review and comment is the Final Environmental Impact
Statement (EIS) for the Metropolitan Wastewater Management Commission
(MWMC) Sludge Management Plan, which is a plan to reuse sludge from the
Eugene-Springfield, Oregon regional wastewater treatment plant.
This EIS was prepared in compliance with the National Environmental Policy
Act and implementing Agency regulations (40 CFR Part 6, November 6, 1979).
Availability of the EIS will be announced in the Federal Register on
June 15, 1984, which will be the start of a 30-day public comment period.
EPA will take no administrative action on this project until the close of
the comment period on July 15, 1984. Following close of the comment
period, EPA will issue a Record of Decision on the federal grant
assistance to be provided for long-term handling of the sludge produced
at the regional treatment plant.
Your review of this document will be appreciated. Any comments you may
have should be addressed to Norma Young, M/S 443, at the above address.
-------
Final
Environmental^ Impact Statement
Metropolitan Wastewater Management Commission
Sludge Management Plan
EPA Project No. C-410624
Prepared by:
U. S. Environmental Protection Agency
Region 10
Seattle, Washington 98101
With technical assistance from:
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, California 95816
Responsible Official:
Ernesta B. Barnes
Regional Administrator
May 3, 1984
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h'rtal
FACILITY:
Municipal Sludge Storage, Conveyance,
Treatment, Drying, and Disposal
Facilities
LOCATION:
Eugene-Springfield, Oregon
DATE:
June 1984
SUMMARY OF ACTION:
A Draft Environmental Impact Statement
(EIS) was distributed in October of
1983 to discuss the environmental
implications of managing municipal
sludge in the Eugene-Springfield,
Oregon area. It considered four
alternative facilities and process
combinations for storing, drying, and
reusing sludge, and looked at four
locations to house the physical facil-
ities. The plan being proposed by the
Metropolitan Wastewater Management
Commission (MWMC), which represents
Eugene, Springfield and Lane County,
Oregon, includes a 5.5-mile digested
sludge conveyance pipeline, mechanical
sludge conditioning, facultative sludge
lagoon storage, air drying beds, and
reuse of the sludge on local
agricultural land. This Final EIS has
been prepared to respond to comments on
the Draft EIS.
FOR FURTHER
INFORMATION:
Ms. Norma Young
Environmental Evaluation Branch
EPA Region 10
1200 Sixth Avenue M/S 443
Seattle, Washington 98101
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TABLE OF CONTENTS
OVERVIEW AND SUMMARY 1
PUBLIC HEARING SUMMARY 7
RESPONSE TO COMMENTS 11
Introduction 11
Groundwater 1.7
Bird Strike Hazard 21
Surface Water/Flooding 22
Soils and Farmland 23
Agricultural Reuse of Sludge 24
Public Health 26
Odors 27
Energy 28
Sludge Quality and Treatment 28
Project Costs and Property Value Effects 29
Alternative Technologies and Sites 31
Landfill Disposal 33
Location of Facilities 34
The Coburg Hills Site 35
Land Use 35
Project Design 36
Errata 37
Other Comments and Questions 38
BIBLIOGRAPHY 41
Literature Cited 41
Personal Communications 41
ACRONYMS AND ABBREVIATIONS 43
LIST OF REPORT PREPARERS 45
U. S. Environmental Protection Agency - Region 10 45
Jones & Stokes Associates, Inc., Sacramento, California 45
APPENDIX A - LETTERS OF COMMENT A-l
APPENDIX B - COST ESTIMATE OF PLASTIC LINER FOR SLUDGE B-l
LAGOONS
APPENDIX C - EIS DISTRIBUTION LIST C-l
111
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LIST OF TABLES
Table Page
1 Recent Population Trends and Projections in the 3
Eugene-Springfield Metropolitan Area
2 Log of Comments 12
v
-------
and. Nummary
The planning for long-term sludge management facilities in
Eugene-Springfield began in 1977 when MWMC contracted with Brown
and Caldwell to prepare a sludge management plan for its new
regional wastewater treatment plant (RWTP) . After several years
of considering a variety of sludge management technologies and
facilities locations, and receiving considerable public input,
MWMC issued a sludge management plan in 1980. Further action on
the plan's recommendations was delayed because of the project's
low standing on the state priority list. In August of 1982 EPA
announced its intention to prepare an EIS on the plan. In
response to these delays, MWMC authorized Brown and Caldwell to
investigate interim sludge management measures that could be
implemented in time to be available when the RWTP begins full-
time operation in the fall of 1984. An interim plan was devel-
oped and published in December of 1982.
After considerable review of the interim (Phase I) plan,
EPA issued a Finding of No Significant Impact (FNSI) on a 5-year
sludge management proposal in July of 1983. The environmental
evaluation of the long-term (Phase II) proposal continued, and a
Draft EIS was released for review at the end of October 1983.
The Draft EIS considered a full array of sludge management
alternatives for Eugene Springfield (see pages 47-60 in the
Draft EIS) . The public hearing on the Draft EIS was held in
Springfield, Oregon on December 6, 1983. Before EPA can take
action on a request for funding for the long-term plan, it must
respond to comments on the Draft EIS and discuss the resolution
of significant environmental issues. This Final EIS has been
prepared to meet those requirements.
EPA's proposed action on the long-term sludge management
plan for Eugene-Springfield is to approve the MWMC preferred
Alternative 2 at the off-site location Site C, which is an
environmentally acceptable solution if certain mitigative
actions are incorporated into the project; it is also the most
cost-effective alternative. The Draft EIS impact evaluation
indicated that Alternative 3 (on-site mechanical dewatering and
agricultural reuse) is the environmentally preferred alterna-
tive, but EPA has determined that Alternative 2 is an acceptable
plan for the following reasons:
1) Alternative 2 is the cost-effective option, with an $8.3
million present worth cost advantage over the on-site
sludge handling alternative (Alternative 3) ; this cost
differential cannot be justified since EPA finds that
the potential impacts of Alternative 2 can be
sufficiently mitigated to make the alternative
environmentally acceptable.
-------
2) Alternative 2 provides a significant energy savings over
Alternative 3.
3) EPA will require that the Site C storage lagoons be in-
stalled with an impervious seal so that full protection
of the groundwater is provided.
4) The treated sludge to be stored and dried at Cite C is
not considered putrescible or of a nature to be
considered a food source for birds or waterfowl; after
thorough review, EPA believes Site C facilities should
not significantly increase the potential for a bird
strike to occur in the vicinity of Mahlon Sweet Field
and, therefore, a bird hazard to aircraft would not be
generated.
5) The impact analysis contained in the Draft EIS indicates
that mitigation measures recommended by EPA are capable
of alleviating Alternative 2's potential adverse im-
pacts, including groundwater contamination. In the
unlikely event that local water supply wells were to be
degraded by the project, however, MWMC would have to
accept responsibility for provision of a potable water
supply for all affected residents until the contamina-
tion is corrected.
Although EPA proposes to approve the MWMC preferred alter-
native at Site C, it intends to strongly recommend that MWMC
delay implementation of Phase II of the Sludge Management Plan
until it has investigated the sludge composting program underway
in the City of Portland. Composting was considered in the early
stages of the MWMC facilities plan development, but Portland has
made considerable progress since that time and expects to have
its facility on-line in May or June of 1984. Also, there are
indications of population decline in the Eugene-Springfield area
since 1980; these declines have not been reflected in projec-
tions of wastewater and sludge handling needs in MWMC planning
documents. The population declines (see Table 1) suggest that
the interim sludge handling solution (Phase I) may be adequate
to service the area beyond the planned 5-year period. With MWMC
on the funding priority list for fiscal year 1985, there is time
to reinvestigate this promising sludge management technology.
EPA recognizes that there could be financial savings to MWMC by
proceeding with the Phase II plan as soon as possible since
dewatering costs could be reduced, but EPA believes that the
Portland sludge handling plan deserves reevaluation. MWMC has
reviewed .a reasonable range of other sludge processing
technologies.
The October 1983 Draft EIS provides a detailed description
of potential impacts associated with the MWMC preferred alterna-
tive. The public review of the Draft has indicated that a
number of these impacts are of special concern. These include:
o Potential contamination of local drinking water supplies
in the vicinity of Site C if sludge components leach
-------
u>
Table 1
Recent Population Trends and Projections in the
Eugene-Springfield Metropolitan Area
1980
1981
1983
1985
(actual)
(actual)
(actual)
(projected)
SPRINGFTKTD1
41,621
39,925
46,127
MWMC
EUGENE SERVICE AREA METRO. AREA LANE CO.
105,664 147,245 193,511 275,226
147,640
103,100
124,206 159,810 221,100 270,867
Actual numbers are from the 1980 census and LOOG; projections for 1985 were made by the cities.
Actual numbers are from LCOG; the projected number was developed by EPA using the 2 percent annual growth
rate assumed by Brown and Caldwell in its Predesign Report.
Actual number is from 1980 census; the projection was made by LCOG.
Actual number is from 1980 census; the projected number is from the Portland State University Center for
Population Research and Census.
-------
through storage lagoons or are carried off-site through
surface drainage.
o Potential surface water quality degradation from sludge
components carried off of Site C during periods of high
groundwater or heavy rain.
o Potential groundwater and surface water contamination at
sludge reuse sites if sludge is applied at greater than
agronomic rates.
o Conversion of 125 acres of farmland from crop production
to storage, treatment, and drying of sludge.
o Possible cropping restrictions in the future on lands
receiving sludge, especially if sludge is applied at
greater than agronomic rates.
o Change in bird use patterns at Site C, increasing fall
and winter use by waterfowl and decreasing year-round
use by passerines, with an accompanying change in the
potential for bird strikes to aircraft using Mahlon
Sweet Field.
o Detectable odors likely to occur within 1,000 feet of
sludge lagoons/air drying beds 10-15 days per year.
o Local user cost increase of $8.33 per year in property
tax and service fees by 1990.
o Project's consistency with local and state land use
planning uncertain due to current state of flux in Lane
County Comprehensive Plan and Zoning Code.
o Property values of land adjacent to Site C possibly
adversely affected if sludge facilities are not properly
operated and maintained.
EPA proposes requiring that MWMC undertake a number of
mitigation measures that would control the potentially adverse
effects of the project. These include:
o Complete the groundwater monitoring effort that is
currently underway at Site C.
o Install an impervious seal/liner in the sludge storage
lagoons.
o Contain all surface runoff from sludge drying beds
on-site year-round.
o Regularly monitor groundwater on the perimeters of Site
C once the Phase II facilities are placed in operation;
if local domestic water wells become contaminated from
-------
Site C facilities (this is not anticipated), provide
affected residents with an alternative water supply
until the contamination is corrected.
o Comply with all DEQ water quality standards and sludge
land disposal guidelines, especially as they relate to
sludge application rates.
o Maintain a regular groundwater quality monitoring
program at representative sludge application sites to
detect changes in groundwater quality.
o Develop sludge spill or pipeline leak contingency plan.
o Maintain and utilize sludge lagoon aeration system
year-round to control odors; if frequent odor problems
develop, implement additional odor control procedures as
described in the Draft EIS.
o Continue to coordinate with Lane County regarding
General Plan and zoning status of Site C (MWMC received
a Conditional Use Permit in February, 1984 for Site C).
The EPA Record of Decision on the Eugene-Springfield Sludge
Management Plan, which will be issued after the Final EIS has
been circulated for a 30-day public comment period, will contain
a final listing of conditions EPA plans to attach to the issu-
ance of a Phase II construction grant to MWMC. This will
include mitigation measures for potential adverse environmental
impacts.
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id Hearing
On Tuesday, December 6f 1983, EPA conducted a public
hearing on the MWMC Sludge Management Plan Draft EIS in Spring-
field, Oregon. The purpose of the hearing was to solicit local
citizen comments on the Draft EIS and the proposed Sludge
Management Plan. Approximately 120 persons attended.
Richard Thiel of EPA Region 10 acted as hearing officer and
led the attendees through a three-part program. The first part
included presentations of the findings in both the Sludge
Management Plan and the Draft EIS. Steve Krugel of Brown and
Caldwell, the Sludge Management Plan engineers, described the
MWMC preferred alternative and its various sludge treatment,
storage, and reuse components. Michael Rushton of Jones &
Stokes Associates, EPA's EIS consultants, then briefly reviewed
the potential environmental impacts of the MWMC preferred plan
and compared them to the impacts of alternative plans. This was
followed by statements from attendees regarding the content of
the Plan and the Draft EIS. Twenty-five persons made formal
statements. The third part of the program was a question and
answer session, with representatives of EPA, Oregon DEQ, MWMC,
Brown and Caldwell, and Jones & Stokes Associates acting as a
panel to respond to comments from the audience.
The entire hearing proceedings were recorded by a court
reporter and subsequently published in the form of a 147-page
hearing record. The hearing was officially in progress from
7:35 p.m. to 12:00 midnight. Due to the extreme length of the
hearing record, EPA decided not to publish it in its entirety in
the Final EIS. Instead, a brief summary of the major questions
and concerns raised during the hearing has been compiled and is
presented below. The complete hearing record is on file with
EPA Region 10 in Seattle. Any person wishing a copy of the
hearing record can remit $29.50 to the U. S. Environmental
Protection Agency and request the document from:
Norma Young M/S 443
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Of the 25 persons making official comments on the Draft
EIS, the vast majority voiced opposition to use of either Site C
or the Coburg Hills Site as a location for long-term sludge
storage and drying facilities. One person spoke in support of
the MWMC preferred plan. Many of the persons opposing the
preferred alternative indicated a preference for another al-
ternative, including the on-site storage and drying option
-------
(Alternative 3) or an enclosed drying/incineration option (Judco
Dryer and O'Connor Incinerator).
The major concern expressed about the use of Site C was the
potential for polluting the groundwater underlying the site.
The local groundwater is the source of all domestic water for
the farms and rural residences in the area and also the City of
Junction City, which is downgradient from the site. Questions
were asked regarding the nutrient, heavy metal, bacterial, and
viral content of the sludge and the effectiveness of design
measures at keeping these materials out of surface runoff or the
groundwater near Site C. The effectiveness of groundwater
monitoring and the ability to clean up the groundwater if it did
become contaminated was also questioned. Many of those who
commented about the use of Site C or the Prairie Road Site are
residents and/or farmers in that area.
Approximately seven people from the Coburg area commented
on the Draft EIS, and all expressed opposition to locating a
sludge storage and drying facility in that area. This included
the President of the City Council, the water commissioner, and
an attorney representing the City, the City Council, the Chamber
of Commerce, and the Muddy Creek Irrigation District. Several
persons questioned why the Coburg site was analyzed in the Draft
EIS when it had been reviewed and subsequently dropped from
consideration in developing the Sludge Management Plan. The
other concerns expressed about the use of this site included
aesthetic impact, groundwater contamination, site flooding,
odors, economic impact, and adverse influence on local property
values. Several persons also felt that the cities of Eugene and
Springfield should not be considering placement of an urban-type
land use outside the metropolitan area urban growth boundary in
a rural setting. Conflicts with state land use planning goals
(agricultural lands, public facility, urbanization, and energy
conservation) were claimed.
In addition to the statements opposing the MWMC preferred
alternative and the use of an off-site location for sludge
storage and drying, a large number of specific questions or
comments were made regarding the content of the Draft EIS. A
listing of the more significant and/or commonly raised concerns
is presented below:
o The latest research on the fate of bacterial and viral
wastewater contaminants should be considered when
assessing the public health impact of land disposal of
sludge.
o The Draft EIS failed to adequately describe why off-site
locations other than Prairie Road, Coburg Hills, and
Site C were not considered in the impact analysis.
-------
o The range of alternative sludge disposal technologies
considered in the Draft EIS should have been greater.
o The agricultural reuse market for municipal sludge is
not adequately documented in the Draft EIS.
o Air-drying of sludge in the Eugene area does not seem
possible; other methods of drying should be considered.
Sludge incineration should also be considered more
fully.
o Much of the groundwater data used in the Draft EIS is
inaccurate, especially the data from the Sweet, Edwards
& Associates River Road/Santa Clara study.
o It will be impossible to avoid sandy or gravelly subsoil
lenses when excavating ponds at Site C or Prairie Road.
o The cities of Eugene and Springfield should handle their
sludge management needs within their own urban growth
boundaries.
o How can MWMC consider using Site C or Prairie Road for
long-term sludge storage and drying when local residents
are not allowed to put additional septic tank/leachfield
systems on their property?
o Why is it more expensive to dewater sludge at the
regional wastewater treatment plant site than at an
off-site location?
o The Site C storage lagoons will attract birds and create
a hazard to air traffic using Mahlon Sweet Field.
o The Delta Gravel Pits should be considered as a sludge
disposal site.
o Site C's value as industrial property should be con-
sidered before it is used for sludge processing.
o Valuable farmland should not be removed from production
for sludge processing purposes.
o Seasonal flooding on Site C and Prairie Road should
eliminate their consideration for sludge processing.
o What course of action would be taken if groundwater
monitoring at Site C shows contamination is occurring?
o What are the land costs at Site C?
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Introduction
EPA received 32 written comments and recorded oral testi-
mony from 28 persons during the official public review period
for the MWMC Sludge Management Plan Draft EIS. Materials were
also received regarding the Agripac wastewater spray irrigation
project and the Eugene RWTP project; these were not considered
relevant to a review of the Draft EIS. Some of this material
was submitted to EPA before the Draft EIS was published and
therefore does not specifically address itself to the content of
the Draft EIS. This material has been reviewed by EPA and is
retained in the project files in Seattle.
A log of all written and oral comments received during the
official 45-day comment period is presented on the following
pages. The name of the agency or individual that commented is
presented, and the subject matter of the relevant comments has
been indicated by placing an "X" in the appropriate column.
Responses to the comments have been organized into a number of
subject matter categories, as indicated in the log of comments,
because of the duplicative nature of many of the comments. Each
individual comment has been carefully reviewed and subsequently
addressed in the text of the general comment sections that
follow. For example, if a commentor voiced a groundwater
concern regarding the proposed project, that person may review
the Groundwater section to find a response. All written com-
ments received on the Draft EIS are included as Appendix A to
this Final EIS. Oral comments that received responses during
the question-and-answer part of the public hearing are not
addressed again in this document.
11
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Table 2. Log of Comments
MWMC Sludge Management Plan Draft EIS
BS
WRITTEN COWENTS
i
a
3 I
CQ
U. S. Dept. of the Army
Corps of Engineers,
Portland Dist.
U. S. Dept. of Housing
and Urban Development
U. S. Dept. of the
Interior, Office of
Secretary
U. S. Dept. of Trans-
portation, Federal
Aviation Administration
U. S. Dept. of Trans-
portation, Urban Mass
Transit Admin.
Oregon Dept. of Fish &
Wildlife
Oregon State Executive
Dept.
Oregon State Historic
Preservation Office
Lane Council of Govern-
ments
12/23/83
12/9/83
2/3/84
12/19/83
11/3/83
12/5/83
2/24/84
2/24/84
12/21/83
X
X
X
X
X
X
X
X
X
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Table 2. Log of Comments
MWMC Sludge Management Plan Draft EIS
WRITTEN COMMENTS
I
E
a
§
en
HQ 3
S §1
§
1
Metropolitan Wastewater
Management Commission
Springfield Area Chambe
of Cormerce
Melva Barnes
Brown and Caldwell
J. Kyle Clinkscales
Mr. and Mrs. William
Cook
Robert Dooley
Gordon Elliott
Joyce Engels
Larry Engels
Ernest Garrett
Howard Humphrey
Donovan Kendall
12/18/83
12/21/83
12/19/83
12/21/83
12/8/83
12/13/83
10/29/83
12/21/83
12/15/83
12/19/83
11/6/83
12/10/83
12/6/83
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
Table 2. Log of Comments
MWMC Sludge Management Plan Draft EIS
Ui
M
Q
a
M
EH
a
WRITTEN COMMENTS
I
§
M
ffl
fe fc!
a
Dan & Ann Klemp
Lois Lund
Richard & Sadie Lyon
Nathaniel D. Mase
Jim Melamed
Bob Meltebeke
Lucille Moyer
John Neely, Jr.
Harold & Lois Schrenk
Chester Swenson
ORAL COMMENTS. AT PIBLIC
Fred Simmons
Jere Christner
Jim Melamed
Bob Bryson
12/21/83
12/16/83
12/8/83
12/16/83
12/6/83
1/9/84
12/21/83
11/7-12/19/i
12/9/83
12/83/83
lEARTNG (12/
X
X
X
X
3 X
X
6/83)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
Table 2. Log of Comments
MWMC Sludge Management Plan Draft EIS
ORAL COMMENTS
J£ S
W OT
i a a
• H B
a
H
8
W
B
Donald Dickey
John Buttner
John Mehringer
Wanda Simnons
Marie Gray
Bob Kaiser
Bob Nelson
Tom Heintz
Chris Coglietti
Herman Bodenroeder
Pat Bohanan
Warren Jacquenod
Katherine Bowder
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
(Jl
-------
Table 2. Log of Comments
MWMC Sludge Management Plan Draft EIS
OPAL COMMENTS
C^
a
I
1
s
a
o
w ffi £ w
-H 1 h a
H H
fe t!
§
[2
Melva Barnes
Gordon Elliott
Judy Wullenwaber
John Neely, Jr.
Ernest Garrett
Bob Parker
James Anderson
Laura Heintz
William Connor
Marlin Franssen
Kirk Poth
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
Groundwater
The groundwater quality issue was by far the most common
subject of comment on the Draft EIS. Thirteen letters of
comment and fourteen oral presentations specifically addressed
the impact of the MWMC project on groundwater quality. The most
prevalent concern was that storage and air-drying of sludge at
Site C or the Prairie Road Site might contaminate local wells,
which provide the sole domestic water source for area residents.
Others indicated that the sludge transport pipeline and the land
application of sludge were likely sources of groundwater con-
tamination. Several questions were raised about the assumptions
made in the EIS groundwater analysis, and the validity of some
of the data used in that analysis was questioned. Another major
topic of comment was the range and effectiveness of groundwater
contamination control measures planned as part of the project.
A variety of other specific, less easily categorized questions
were raised about groundwater in the vicinity of the proposed
project.
The response to this diversity of groundwater comments has
been organized into three sections. The first addresses all
questions about the technical detail of the Draft EIS ground-
water analysis. Description of existing groundwater conditions
is the major topic of this section. The second section address-
es questions about the design of the sludge handling facilities
and their effectiveness in controlling groundwater contamina-
tion. The final section addresses a number of miscellaneous
questions.
The groundwater quality analysis in the Draft EIS was
lengthy; it summarized a considerable volume of data and an-
alyzed groundwater conditions at a large number of sites. The
sources of background data for this analysis are existing
reports and monitoring data. No original data collection was
undertaken by EIS preparers, but efforts were made to use the
most recent, most site-specific data available. Sweet, Edwards
& Associates (1982) data from the Agripac site were used in
reference to Site C and Prairie Road because it is both recent
and site-specific. EPA has not received any substantive
evidence that this data is inaccurate or invalid. If there is
specific reason to question this data, EPA would appreciate
being informed of what is inaccurate or misleading. In several
instances, background data that are 10 to 15 years old were used
(Frank and Johnson 1970; Frank 1973). This was considered
appropriate where more recent or more specific data is not found
in the literature. Most of the older literature provided only
general groundwater flow direction data. It is unlikely that
this has changed significantly in recent years. The groundwater
flow rate at Site C has not been measured by MWMC; the EIS
preparers, therefore, relied on data developed by Sweet,
Edwards & Associates for a nearby section of the aquifer.
17
-------
A question was asked regarding the migration of leachate
out of the sludge lagoons if some failure occurred during
periods of high groundwater. The EIS contention that leaching
would "virtually cease" in the fall and winter due to a rise in
the water table was questioned. The commentor felt that mound-
ing would occur and horizontal leachate migration would contin-
ue. We agree that leachate migration probably would not totally
cease. Migration would be greatly reduced, however, if the
general groundwater level reached the bottom of the lagoons or
the surrounding ground surface level. Mounding could occur if
the groundwater level remained some distance below the bottom of
the lagoons. In this situation, some lateral movement of
leachate could be expected. The significance of lateral migra-
tion would depend on the volume and quality of the leachate and
its rate of movement and mixing. Off-site effects probably
would be detected sooner in the mounded groundwater situation
than if the underlying groundwater level was at or near the
surface.
Several commentors asked about the depth of the clay soils
at Site C. Concern was expressed that excavation for the sludge
lagoons might intercept coarser sand or gravel, increasing the
risk of eventual groundwater contamination. As indicated in the
Draft EIS (page 84) , there may be locations where the depth of
clay soil is less than 5 feet and coarser material may be
encountered. The project engineers planned to cover such areas
with a minimum of 6 inches of compacted clay material excavated
from some other location. EPA is requiring that an impervious
seal be installed in all lagoons to ensure that leachate mi-
gration is controlled even if coarse subsoil layers are encoun-
tered during excavation. Soil borings made in the Site C area
to date indicate that clay soils extend from 4 to 18 feet below
the surface, with gravelly silty sand found at the surface in
one well boring (Geotechnical Consultants, Inc. pers. comm.).
Many of the groundwater comments indicated a fear that
contamination would occur in spite of features that would be
designed into the proposed project to protect groundwater
quality. Two persons felt that the ponding of surface water
that often occurs in the area in winter months would lead to
groundwater contamination if the sludge facilities were located
in this area. The project design, however, calls for con-
struction of 5-foot high berms around all sludge lagoons, and
air-drying beds would not be used in the winter months. Ponded
or flowing surface water, therefore, should not come into
contact with sludge.
EPA is aware of fears that a 6-inch clay liner in all
sludge lagoons might not be sufficient to avoid eventual ground-
water contamination. Because there is a significant number of
persons that rely on shallow groundwater for domestic consump-
tion in the Site C area and coarse subsoil layers may be encoun-
tered in lagoon construction, EPA is requiring MWMC to install
an impervious seal in the lagoons. This should provide maximum
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groundwater protection. MWMC has estimated the additional cost
of a plastic liner would be approximately $960,000 (see Appen-
dix B). Other types of liner or seal may be possible.
The dual force mains that would carry sludge and super-
natant between the RWTP and the off-site facilities were also
sources of concern. In its comments, Brown and Caldwell noted
that the dual nature of this line could reduce the likelihood of
serious groundwater contamination. If a leak (or break) was
detected in one line, the second line could be used for trans-
port of materials while the damage in the other line was re-
paired. Problems of exfiltration from unsealed joints or
vibration damage can be controlled through proper design and
construction; these problems can be located, if they do occur,
through periodic pressure testing. It will be MWMC's respon-
sibility to ensure that pipelines are properly designed and
constructed.
Several persons questioned the need for groundwater quality
monitoring in the vicinity of Site C if the project was not
expected to contaminate the groundwater. Others asked what
would happen if monitoring detected some contamination. Ground-
water monitoring is an essential part of plans for sludge reuse
in the Eugene-Springfield area; it will serve a number of
valuable functions. First, ,a monitoring system will provide
background water quality data, whether it be at the storage and
drying site, at Short Mountain Landfill, or at sludge reuse
sites. If all facilities and operations perform as expected,
the monitoring data will act as an indicator that groundwater
contamination is not occurring. If for any reason, however, the
sludge management operation does cause a change in groundwater
quality, the monitoring program will allow early detection.
Modification of facilities or changes in operational procedures
can then be undertaken to control the source of the contamina-
tion. The nature of these changes would depend upon what is
found to be the source of contamination.
The nature of the aquifers at Site C make it unlikely that
groundwater contamination in the area would be corrected by
extracting and treating the water. An extraction barrier might
be created, but rapid location and correction of the source of
contamination would be the critical action. If local domestic
water supply wells were to become contaminated, MWMC would be
responsible for procuring an alternative water supply for the
affected residents until the contamination had been corrected.
Control of the source of contamination and dilution of the con-
taminants in the groundwater as they move with the general
groundwater flow may be the only effective remedial action.
The same general remedial procedure would apply at Short Moun-
tain Landfill if a change in groundwater quality were detected.
Groundwater monitoring at sludge reuse sites would serve
the same function as at the storage and drying site. Any change
in groundwater quality caused by sludge reuse would be detected
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and a change in application would be initiated. If the source
of the problem was an excessive rate of application, an adjust-
ment in rates could be made. If the problem was found to be
associated with site drainage or permeability conditions, or
excessively low soil pH, it might be necessary to halt sludge
reuse at that particular site.
In summary, there are numerous features designed into MWMCs
preferred sludge management plan to reduce the chances of
adversely affecting groundwater. Every effort will be made to
guarantee that all of the features are constructed and operated
as designed. The groundwater monitoring system will provide
back-up protection. EPA will not require MWMC to post a bond
for correction of water supply contamination, but MWMC will have
the responsibility for correcting problems associated with its
sludge management facilities.
The final section of this groundwater discussion deals with
several specific questions that could not be answered in a
collective response. These questions and their responses are
presented below.
Why has MWMC not considered use of government land south of Fern
Ridge Reservoir for sludge reuse? The land is not over the
aquifer supplying domestic wells. MWMC intends to apply
its sludge to agricultural lands to take advantage of its
nutrient value. If the government land south of Fern Ridge
Reservoir is used for agriculture and can meet DEQ land
application criteria, MWMC would consider its use.
Why are the Delta Pits unacceptable for sludge storage, yet Site
C is acceptable even though gravelly subsoils may be
encountered? The reasons for rejecting use of the Delta
Pits is stated on pages 56-57 of the Draft EIS. Lagoons at
Site C would not be placed on a large expanse of open
gravel as would be the case at the Delta Pits. Only small
lenses are expected to be encountered at Site C. The
lagoons would be lined with impervious material.
What is the depth to groundwater at Site C at this time?
Groundwater monitoring at Site C shows that depth to
groundwater has fluctuated between less than one foot to 11
feet below the surface in the last year (Peroutka pers.
comm.).
Would agitation action from train-related vibrations cause
groundwater to intermix with sludge lagoon leachate at Site
C or Prairie Road? The sludge lagoons are not expected to
generate leachate, as an impervious seal is being required
by EPA. With an impervious liner, train-related vibrations
are not expected to have any effect on leakage or ground-
water.
The EIS contention on page 84 that ammonia-nitrogen moves freely
through the soil is inaccurate. It is readily bound up
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with soil. EPA agrees that the statement on page 84 is
inaccurate. Reference should have been to nitrate rather
than ammonia-nitrogen.
A North Carolina study indicates that sludge should not be
applied to soils with a pH less than 6.5. Low pH allows
heavy metals and other materials to move rapidly through
the soil. The Oregon DEQ recognizes soil pH is a signifi-
cant factor in the movement of heavy metals through soils.
Its sludge reuse guidelines have accounted for this by
allowing lower cumulative application rates where pH is
less than 6.5 (see page F-20 of the Draft EIS) . DEQ has
reviewed the literature on this subject, and does not feel
that sludge reuse should be totally eliminated on soils
with a pH less than 6.5.
Bird Strike Hazard
Several commentors voiced continued concern over the hazard
that the project might create if it becomes a bird attractant.
This included local residents and the Federal Aviation Adminis-
tration. The principal issues raised in these comments were
addressed in the Draft EIS on pages 140-157, but will be restat-
ed here briefly.
The concern over the bird strike hazard is based on FAA
Order 5200.5, which discourages the location of any solid waste
disposal facility that might act as a bird attractant within
10,000 feet of airport runways used by turbo-jet aircraft. EPA
has adopted a similar policy regarding the processing or dis-
posal of putrescible wastes within 10,000 feet of a runway.
Residents have stated that the planned sludge storage lagoons
and sludge drying beds, which are located less than 10,000 feet
from Mahlon Sweet Field Runway 3-21, are likely to act as a bird
attractant and therefore are in conflict with FAA and EPA
policy.
EPA researched this issue thoroughly in preparing the Draft
EIS. Persons with considerable knowledge of local bird use
patterns, bird use at similar sludge facilities, and bird strike
hazards at airports were consulted. This included FAA represen-
tatives in Seattle, Minneapolis, and Washington, D. C., and
treatment plant operators in Corvallis and Sacramento. The two
critical questions addressed in assessing the hazard were: 1)
would the new facilities act as a bird attractant, and 2) would
any project-related change in bird use constitute an increased
risk of bird strikes to aircraft using Mahlon Sweet Field?
After reviewing all aspects of facility design and the
relationship of Site C to the Runway 3-21 flight pattern,
several important factors came to light. First, the sludge to
be stored and dried at Site C would be digested and essentially
stabilized before arriving at the site. The material will not
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be putrescible (containing organic matter capable of being
decomposed by microorganisms) and, therefore, should not act as
a food source to birds. Further, operation of the facility,
including use of aerators and control of aquatic vegetation
within the lagoons, should further discourage bird use of the
site. Finally, aircraft using Runway 3-21 would pass approxi-
mately 400-600 feet overhead of Site C, considerably above the
normal flight elevation of most birds presently known to inhabit
the area (waterfowl are an exception).
Based on this review of information, we concluded that the
sludge facilities would not act as a significant attractant to
birds, although waterfowl may occasionally use the lagoons for
resting. There are already numerous open water areas in the
vicinity that provide resting areas and also a source of food
for waterfowl, and it is unlikely that waterfowl would use
"poor" quality water (sludge) for resting, given abundant
alternatives. The project-related change in local bird use
patterns is not expected to significantly increase the probabil-
ity of a bird strike occurring in the vicinity of Mahlon Sweet
Field.
In order to ensure that any facilities located at Site C
would not act as a bird attractant, EPA has recommended a number
of control measures. These include control of aquatic vegeta-
tion in the lagoons, day-time use of aerators and monitoring of
bird use patterns. In the unforeseen event that birds may be
attracted to the lagoons and create a bona fide hazard, it will
be MWMC's responsibility to mitigate the problem.
Surface Water/Flooding
Surface water quality and site flooding concerns were
indicated in a number of comments. The chief concern was that
runoff from or flooding at Site C would contaminate surface
water or groundwater to the north. Reference to Federal Emer-
gency Management Agency (FEMA) flood hazard boundary maps was
made by two individuals. The February 1981 flood hazard maps
show a Zone A flood zone along the drainage that traverses the
portion of Site C analyzed as part of Alternative 1. It does
not cross the southern portion of Site C analyzed as the MWMC
preferred alternative (Alternative 2).
Lane County was contacted to determine if more recent flood
hazard maps showed any change in the boundaries of flood hazard
at Site C or Prairie Road. FEMA maps of Lane County published
on September 16, 1983, indicate that the drainage channel that
traverses Site C (the northern portion) from southeast to
northwest is still classified as a Zone A flood hazard area.
This suggests that if MWMC wishes to use this northern portion
of Site C for sludge handling facilities, the drainage channel
must be diverted around the facilities. EPA would require
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that the facilities be flood-proofed for the 100-year
flood event. This would be required as a condition of construc-
tion grant approval.
The possibility of surface water contamination at Site C
has been taken into consideration in the proposed design and
operation of the lagoons and drying beds. Runoff and flooding
control measures are discussed on pages 111-113 of the Draft
EIS. Rerouting of the surface drainage around Site C, collec-
tion of runoff from those areas likely to come in contact with
sludge, and fall washdown of sludge drying beds are several of
the project features planned to control surface water contamina-
tion. If off-site drainage from the lagoons, drying beds, and
sludge transfer facilities are contained on-site as planned and
pumped back into the lagoons, and if the existing drainage
channel is diverted around Site C, surface water contamination
should not occur downstream from the site.
The Lane Council of Governments expressed concern that
there is a lack of water quality data for the surface waters
near Site C, the Prairie Road Site, and the Coburg Hills Site.
This lack of data is typical when the local surface waters are
intermittent streams. Very few intermittent streams are moni-
tored throughout the United States. It is likely that agricul-
tural runoff now contributes nutrients, bacteria, and perhaps
pesticide or herbicide residues to these waters when they are
flowing. If Site C is developed for sludge storage and drying,
a surface water sampling program must be initiated prior to
construction. These data will be essential as a background
comparison for future monitoring results. The lack of data on
existing surface water quality conditions, however, need not
influence the decision on whether or not to proceed with con-
struction of off-site sludge handling facilities.
Soils and Farmland
Five persons indicated their opposition to the conversion
of prime farmland for construction of off-site sludge storage
and drying facilities. In contrast, the Sludge Management Plan
engineers (Brown and Caldwell) indicated that the land at Site C
should not be considered prime farmland because of the complex
patterns of Class II and Class IV soils that exist on the site
and the poor drainage conditions present on the site. Brown and
Caldwell contends these conditions limit the use of the entire
site as prime farmland.
It is EPA's policy to consider protection of the nation's
significant agricultural lands from irreversible conversion to
nonagricultural uses. In the case of Site C, the land has not
been categorized as prime or unique farmland under the U. S.
Soil Conservation Service Land Inventorying and Monitoring
Memorandum (LIM) criteria. Lane County, however, has mapped the
site as a combination of prime and unique farmland. EPA recog-
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nizes that poor drainage conditions on the site and the alter-
nating pattern of well drained and poorly drained soil restrict
the range of farming practices that are undertaken on the
property. The site is currently used for grass seed production
rather than a food crop. Nonetheless, EPA feels that the loss
of 80-100 acres of Class II soil at Site C is an adverse impact
of the MWMC preferred project, although it is not an irrevers-
ible and irretrievable loss. The significance of this loss of
soil resources has been weighed against the environmental and
economic implications of other sludge management alternatives.
If MWMC pursues grant funds for use of Site C, EPA will fund
purchase of only that acreage needed to accommodate the 20-year
design capacity of the facilities. EPA will also recommend that
the facilities be located on the site in a manner that least
interferes with continued agricultural use of surrounding
parcels.
Agricultural Reuse of Sludge
A major component of the MWMC Sludge Management Plan is the
reuse of liquid and air-dried sludge on Willamette Valley
agricultural lands. A demonstration reuse program has been
underway for several years now, using sludge from the Eugene
wastewater treatment plant. Estimates prepared by Brown and
Caldwell indicate that up to 2,050 acres of agricultural land
will be needed by the year 2000 to reuse all sludge generated by
the new Eugene RWTP. A number of persons commenting on the
Draft EIS felt that there was insufficient evidence of the local
farmers' willingness to accept the sludge.
A number of reasons why local farmers might not be willing
to accept the sludge were expressed. This included such con-
cerns as heavy metal accumulation, low nutrient content, future
restrictions on crop types, competition for land from urban
uses, potential for changes in regulations, and general mistrust
of local city government. Several persons requested proof of a
demand for the product, including a list of names and numbers of
acres committed to accepting the sludge.
EPA has had considerable experience with municipal sludge
reuse proposals throughout the U. S., including projects in the
Northwest. This experience shows that there is usually an
initial hesitancy toward sludge reuse, but in the majority of
cases agricultural reuse programs have proven successful in the
long term. There is a wide array of control measures available
to protect soil resources and the public health from ill effects
of agricultural reuse of sludge. The MWMC has initiated a
pretreatment program to limit the amount of potentially harmful
materials that enter the RWTP. DEQ and MWMC regulations and
guidelines restrict the amount of heavy metals that may be
applied to a given parcel of land. The sludge may not be
applied to land being used to raise food crops. Therefore, no
land will be taken out of food crop production. Other guide-
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lines restrict public access and grazing activity on land
receiving sludge. A comprehensive soil monitoring program is
also required.
EPA has not required MWMC to provide a listing of individ-
uals or specific acreages that would receive the sludge product.
Experience with other projects and an independent review of the
agricultural reuse market in the Eugene area (see pages G-6 to
G-ll in the Draft EIS) indicate that the sludge should have
sufficient value as fertilizer and soil conditioner to attract
users, as long as the reuse is closely monitored by both DEQ and
MWMC. EPA also feels that subsidiary markets in forestry and
speciality fields (nurseries, landscapers) could be acceptable
outlets for sludge in the Eugene area. EPA does not believe
that there will be a lack of reuse opportunities after the
storage and drying facilities are constructed.
Several other questions were raised regarding the agricul-
tural reuse of sludge. One person asked if the reuse aspect of
the plan would make MWMC eligible for an additional 10 percent
federal funding as an innovative or alternative technology. As
an alternative technology, the sludge reuse aspect of the
project makes MWMC eligible for an additional 10 percent grant
funding. However, this extra 10 percent is subject to the
availability of federal funds.
Two persons questioned the public health consequences of
agricultural reuse and wondered why the sludge could be applied
to agricultural land but not to urbanized settings such as parks
and greenbelts. There is sufficient evidence in the scientific
literature to indicate that the controlled application of
treated municipal sludge to nonfood crop agricultural land can
be accomplished without significant risk to public health.
Agricultural lands are typically not subject to general public
entry, and access can be closely controlled. Farmers will
receive sludge on a voluntary basis only, after being informed
of any potential health risks. This controlled access and
implied consent cannot be achieved where the sludge is placed on
public parks or greenbelts. Sludge is being applied to agri-
cultural land in many parts of the United States without
apparent adverse health effects.
Brown and Caldwell questioned the conclusion in the EIS
that use of air-dried sludge on agricultural lands (Alterna-
tive 2) would create more significant heavy metals problems in
surface waters than would use of dewatered sludge (Alterna-
tive 3) . EPA bases its contention on the fact that the total
amount of heavy metals applied per acre would be less annually
using dewatered sludge than using air-dried sludge. This is
because the ratio of heavy metals to nitrogen is lower in a
sludge that has not been subjected to thorough air-drying.
Soils should be able to absorb the smaller amounts of heavy
metals more rapidly under the dewatering mode, thus reducing the
risk that the metals could be washed into surface waters before
being assimilated into the soil.
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Public Health
The public health risks associated with sludge processing
and disposal have been a dominant issue in the MWMC sludge
management planning effort. The comments received during the
Draft EIS review process focused on a continuing concern—the
health hazard associated with applying sludge to agricultural
lands. Several commentors specifically identified the cadmium
content of the sludge as a health hazard. Others felt that
viruses, bacteria, and heavy metals in general pose a threat to
human health and should be kept off the land. Transfer of toxic
materials to humans through consumption of plants or animals
raised on the land was also expressed as a public health con-
cern.
Both EPA and the Oregon DEQ are aware of the potential
health hazards associated with agricultural reuse of sludge. In
order to provide for maximum public protection while still
taking advantage of the fertilizer and soil conditioning value
of municipal sludge, EPA and DEQ have established rigid controls
on agricultural reuse. These controls have been established
through review and analysis of the numerous public health
studies that have been conducted by universities and state and
federal agencies. The public health analysis contained in the
Draft EIS (pages 124-136) was prepared after review of the most
recent public health literature and was compiled by a specialist
in bacteriology and public health. After considering the degree
of treatment the sludge will receive, the expected quality of
the sludge, and the high degree of control and monitoring of
agricultural reuse required by DEQ, EPA concludes that the
sludge can be applied to the land in the Eugene-Springfield area
without creating a significant public health threat.
Bacterial and viral levels in the sludge will be greatly
reduced by the digestion, storage, and air-drying processes
proposed for use. Heavy metal content, which is relatively low
in Eugene-Springfield sludge, will be closely monitored and
limits will be established for each land area receiving sludge.
Sludge will not be applied to food crops, so plant uptake will
not be a public health risk. The heavy metal limits, including
limits for cadmium, will provide a 100-1,000 fold safety factor
for any given year. It will take an estimated 65-167 years to
reach the maximum allowable heavy metal loading on reuse sites,
assuming maximum allowable applications of sludge. If cadmium
levels are found to be twice as high as expected by Brown and
Caldwell, this life expectancy could be reduced to 32 or 33
years. In any event, soil monitoring will ensure that heavy
metals are not allowed to build up to hazardous levels on any
sludge disposal site.
Two persons indicated that studies have shown septic tank
treatment of human wastes poses less of a public health threat
than activated sludge treatment in a central wastewater treat-
ment facility. There are numerous studies that indicate septic
tank/leach field systems are effective wastewater treatment
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systems when soil and groundwater conditions are appropriate,
but these systems cannot be used effectively in densely popu-
lated areas. Sludges generated in activated sludge wastewater
treatment plants can be disposed of or reused without a serious
health risk if properly digested and treated prior to disposal
or reuse. Septic tank/leach field systems are not a viable
alternative to MWMC's proposed Sludge Management Plan.
Several persons also expressed the fear that toxics in the
sludge applied to agricultural land would be taken up by plants
and subsequently pose a health hazard to humans. As stated
earlier, DEQ regulations (adopted by MWMC) do not allow applica-
tion of sludge to food crops. An 18-month waiting period must
be observed between sludge application and planting of food
crops. This is expected to provide sufficient time for any
pathogenic agents to die off; soil and plant tissue samples can
be taken to ensure that hazardous levels of potentially toxic
materials are not transferred to crops that may be consumed by
humans. It is unlikely, also, that lands receiving sludge in
the Eugene-Springfield area will switch from growing nonfood
chain crops to growing food chain crops.
One commentor questioned the statement in the Draft EIS
that composted sludge would have a lower level of pathogens than
air-dried, dewatered, or liquid sludge. EPA agrees that patho-
gen die-off in facultative sludge lagoons can approach that
achieved through composting, given an adequate retention time in
the lagoon.
Odors
A concern about odor problems in the Site C/Prairie Road
area was expressed by seven commentors. No specific questions
or comments were made about the odor analysis in the EIS, but
the commentors felt that odors would significantly affect
persons living near the facilities. One commentor felt that
odor problems would occur more frequently than indicated in the
Draft EIS.
EPA agrees that odors are likely to occur at times in the
vicinity of the sludge lagoons and drying beds. The frequency
of these problems will depend in part upon the frequency of
inversions, the distance from the facilities, and the effective-
ness of operating techniques designed to minimize odor gen-
eration. It is impossible to predict the absolute frequency and
significance of odor problems. This is one reason for selecting
a rural setting for the facilities. EPA has recommended a
number of actions that could be taken by MWMC if significant
odor problems develop in the vicinity of the off-site facilities
(see pages 179-181 of the Draft EIS and page 5 of this docu-
ment) .
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Energy
Brown and Caldwell indicated that the energy analysis in
the Draft EIS did not consider several secondary energy demands
associated with mechanical dewatering alternatives (Alterna-
tive 3 and, to a lesser degree, Alternative 2). These energy
demands include polymer production and recycle treatment of the
liquid removed from sludge. The energy saved by replacing
commercial fertilizers with sludge was also not considered in
the Draft EIS.
These secondary energy use factors are legitimate elements
of the EIS analysis. While specific numbers have not been
generated here, the energy demands for Alternative 3 would be
even greater in relation to Alternatives 1 and 2 than is shown
in Table 3-14 of the Draft EIS (page 169) if the polymer produc-
tion and recycle treatment energy demands were considered.
Alternatives 1 and 2 would also show a greater energy use
advantage over Alternative 3 if the energy value of fertilizers
were considered. The consideration of these secondary energy
factors reinforces EPA's contention that Alternative 3 has a
very distinct energy consumption disadvantage when compared to
Alternatives 1 and 2 (see the Overview and Summary section at
the beginning of the Final EIS).
Sludge Quality and Treatment
The sludge quality and sludge treatment processes assumed
in preparing the Draft EIS were questioned in two letters.
Several specific questions were asked about the levels of
cadmium, PCBs, mercury, and other potentially hazardous sub-
stances that would be in the sludge when it reached off-site
storage lagoons. The question was also raised as to whether the
sludge should be considered putrescible or nonputrescible when
it reaches the off-site facilities.
The most detailed analysis of sludge constituents in the
Eugene-Springfield systems was conducted by MWMC in April
through August of 1978. The results of this analysis are
reported in Tables B-l and B-2 of the Draft EIS (pages B-3 and
B-4) . These numbers are expected to be indicative of the
quality of sludge that will be produced at the new RWTP, al-
though some variation will occur due to changes over time in
influent concentrations and the change in wastewater and sludge
treatment processes. The MWMC pretreatment program has been
approved and will cause some reduction to occur in certain
sludge constituents. This includes metals and salts. Much of
the metals and salts that, in the past, were discharged to the
sewer system by industrial sources, will be removed at the site
of use prior to discharge to the sewer system. These materials
will, in turn, have to be recycled, treated on-site, or trans-
ported to an acceptable land disposal site. This could include
Short Mountain Landfill if the materials are not considered
hazardous. If the materials are considered a hazardous waste,
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they must be transferred to the hazardous waste disposal
facility at Arlington, Oregon. The exact nature of the sludge
produced by the new RWTP will not be known until it is in
operation. Extensive sludge testing will occur once the plant
is on-line. The sludge may continue to contain small
amounts of heavy metals (cadmium, mercury, lead, zinc) and some
chlorinated hydrocarbons from uncontrolled disposal of materials
through residential sewer hookups. No radioactive materials are
expected in the sludge.
Two persons questioned whether the sludge stored in off-
site lagoons should be classified as putrescible. A review of
the proposed sludge digestion and lagoon storage processes and
consultation with EPA personnel in Cincinnati, Ohio indicate the
sludge to be spread on drying beds at Site C or any off-site
location would be nonputrescible. The materials stored in the
facultative sludge lagoons may be in part putrescible, but would
be covered by several feet of clear water and, therefore, would
not be available to birds.
In response to a question about sludge retention time in
digesters, the average retention time will be 17 days at the new
RWTP.
Finally, a question was raised regarding the safe level of
cadmium in sludge. The Oregon DEQ sludge application guidelines
indicate that 25 mg/kg of cadmium is acceptable for general
application to agricultural land. Testing of Eugene-Springfield
sludge in 1978 indicated 6.1 to 7.7 mg/kg of cadmium in the
sludge. The annual application rate cannot exceed 2.0 kg/ha
according to DEQ and EPA guidelines (for further discussion, see
pages 108 and 109 of the Draft EIS).
Project Costs and Property Value Effects
Five persons commented on project-related costs. Informa-
tional requests included the cost of dewatering equipment at the
treatment plant and Site C; clarification of user costs, partic-
ularly those related to River Road/Santa Clara residents; land
acquisition costs, and the effect on project economics; the cost
of certain drying and incineration technology; and the use of
federal funds for MWMC projects. Four individuals commented on
the project's effect on property values.
With respect to the relative cost of dewatering equipment
at the treatment plant and Site C, the proposed treatment
processes are substantially different, thereby making cost
estimations and comparisons difficult. At the treatment plant
site, dewatering would occur primarily with the use of capital-
and energy-intensive centrifuges. As described on page 58 of
the Draft EIS, significant on-site improvements would be re-
quired for this alternative. As shown in Table 2-4 on page 59
of the Draft EIS, the present worth capital costs associated
with Alternative 3 (treatment at the existing plant) are $9.1
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million. Dewatering equipment at Site C consists primarily of
centrifuges to be relocated from the existing treatment plant,
air drying beds, and lagoons. Under this alternative, centri-
fuges would not be used to produce a final dewatered product but
rather for initial dewatering. This would significantly reduce
centrifuge energy costs at Site C. The present worth capital
costs of the Site C alternative are estimated to be between $4.5
million and $4.9 million. In summary, the capital and energy
requirements of relying only on centrifuges for dewatering
significantly increase project costs.
With respect to user costs, the $10.50 per month currently
charged to Eugene and Springfield residents covers only opera-
tion and maintenance costs of the Lane County Metropolitan
Wastewater Service District and of the Cities of Eugene and
Springfield. Funds for servicing of the bond debt for the local
share of capital costs of the regional wastewater treatment
system are provided by local property tax revenues. User costs
to future service areas such as residents of the River
Road/Santa Clara area will be the same as costs to other users
within the service area. By the time residents of these areas
are connected to the system, however, user costs are likely to
increase above their current levels.
According to the project engineer (Krugel pers. comm.),
land acquisition costs at Site C were assumed to be $4,900 per
acre in the analysis of project costs. Actual estimates which
were made prior to cost projections were somewhat less, but were
adjusted to current dollars by the Engineering News Record (ENR)
index.
During preliminary stages of the project, a variety of
alternative technologies were evaluated by the project engi-
neers. Although the Judco Dryer and O'Connor solid waste burner
combination was not looked at specifically, incineration of
sludge was evaluated. On-site incineration of sewage sludge was
dropped from further consideration because of the following
problems: air pollution, poor economics, resources consumption,
exclusion of existing uses and nonuse of existing facilities,
inflexibility and unreliability, and public image. It should be
noted that because all sludge management technologies have
certain advantages and disadvantages which may or may not be
appropriate for a particular area, EPA does not require use of
specific technologies; rather, the local management authority
and their project engineers are responsible for evaluating and
selecting technologies most suitable for their sludge management
needs.
The purpose of EPA's construction grant program for waste-
water facilities is to improve the quality of the nation's
waters through more effective treatment and disposal of waste-
water and wastewater products. As mandated by the Clean Water
Act of 1977, this program distributes funds to the states for
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facility planning and construction. The states then allocate
these funds based on a priority list.
The potential effect of the project on adjacent property
values involves the interaction of a variety of potentially
important factors. Operating conditions at the facility and the
type of adjacent land uses, however, are two key elements.
Because uncertainty regarding the potential effects of a sludge
management project is greatest at the outset, some initial
market reaction to the project can be expected. Over the long
term, however, the key factor likely will be whether the sludge
management facility turns out to be a "good neighbor." Condi-
tions imposed on the project regarding odor control and visual
and noise buffers are designed to minimize potential land use
conflicts and to ensure land use compatibility.
Unfortunately, property value effects can only be accur-
ately determined over time. Based on other local experiences,
however, such as in Salem, the siting of this type of facility
in areas predominantly agricultural has not resulted in an
adverse effect on property values. With proper operation and
maintenance of the facility, and assuming that adjacent lands
remain predominantly agricultural, the long-term effect on
property values from the project should be negligible.
Alternative Technologies and Sites
A wide range of comments was made regarding the alterna-
tives analysis contained in the Draft EIS. An attorney repre-
senting the City of Coburg felt the EIS did not consider an
adequate range of alternatives. He also questioned the process
adding the Coburg Hills Site to the list of alternative sites
analyzed in the EIS. A number of conunentors voiced support for
alternatives not studied by MWMC, including the Judco dryer with
incineration. Alternative 3 (on-site mechanical dewatering with
agricultural reuse and landfill disposal) also received support.
Other questions were raised regarding septic tanks, dedicated
land disposal, the Four Corners off-site location, and the
no-action option.
The range of alternatives analyzed in the Draft EIS was
determined by a thorough review of the Sludge Management Plan
alternatives development and screening process, in-house anal-
ysis of sludge reuse options in the Eugene-Springfield area,
numerous discussions among EPA, DEQ, MWMC, and Brown and
Caldwell staff. Pages 29-60 of the Draft EIS describe the
alternatives development and screening process used by EPA and
the project engineers and identify the range of alternatives
finally considered in the EIS. Rationale for elimination of
alternatives is presented on pages 56 and 57 of the Draft EIS.
The EIS analyzes two sludge processing alternatives (lagoon
storage with air drying and mechanical dewatering) , five sludge
disposal/reuse options (landfilling, agricultural reuse,
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forestry reuse, home and garden reuse, speciality market reuse),
and four sites for sludge processing facilities (the RWTP site,
Site C, the Coburg Hills Site, and the Prairie Road Site). This
represents a reasonable range of feasible options for the
Eugene-Springfield area.
The range of alternative locations for facilities was
established after a thorough staff evaluation of all sites
considered in the sludge management planning process. Seventeen
sites were visited in the field and the MWMC criteria for
rejection were reviewed. As a result, the MWMC preferred site
(Site C) and three sites rejected by MWMC (Prairie Road, Coburg
Hills, RWTP site) were retained for full evaluation in the EIS.
The Four Corners Site was rejected after it was learned that the
City of Eugene held title to a portion of the site and was
actively considering development of the area as a regional park.
This was considered a legitimate rationale for dropping the
site. The Coburg Hills Site was retained for consideration
because it appeared to offer a degree of remoteness and lack of
visible land use conflicts compared to the MWMC preferred site.
The landowner and the Mayor of Coburg were notified early in the
process (Spring 1983) that the site was to be considered in the
Draft EIS.
A number of people suggested the Judco dryer system or
Alternative 3 should be considered as replacements for the MWMC
preferred plan. EPA's role in reviewing the Sludge Management
Plan and preparing this EIS is to act as a funding agency as
outlined in the Clean Water Act. The environmental evaluation
is not a facilities planning effort. It is the responsibility
of the entity applying for .federal grant funds (MWMC) and its
engineering consultants (Brown and Caldwell) to identify and
consider viable options for handling wastewater and sludge
facilities needs. The local entity is responsible for consider-
ing any technologies of interest to local residents. EPA
normally does not reject or request modifications in the alter-
natives evaluation process unless the range of options consid-
ered is obviously lacking in relation to the range of technolo-
gies known to be effective. EPA has seen no grounds to reject
the alternatives evaluation and selection process used by MWMC
or to require MWMC to pursue use of the Judco dryer system. As
indicated in the Overview and Summary section of this report,
EPA has determined that Alternative 3 is the environmentally
preferred alternative. Because of its considerable extra cost
and extreme energy demand, however, EPA has determined that
Alternative 2 is an acceptable plan if potential adverse impacts
are properly mitigated.
Use of septic tanks and the Delta Pits was recommended by
commentors. As indicated in an earlier section, septic tanks
are not an acceptable wastewater treatment option in densely
populated urban areas, and they are not a feasible option for
handling the sludge that will be generated at the new Eugene
RWTP. The Delta Pits have also been considered by EPA and are
32
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not considered an acceptable sludge disposal solution. The
rationale for rejection of the Delta Pits is presented on pages
56 and 57 of the Draft EIS.
Two persons felt that MWMC would eventually resort to a
dedicated land disposal (OLD) method of sludge disposal if the
air-drying and agricultural reuse system did not function
properly. There also was fear that this DLD would be located at
the off-site storage and drying site. EPA does not intend to
fund a DLD project for MWMC, nor is DLD at the off-site location
proposed for the project.
One commentor stated that if a no-project option were truly
implemented by MWMC, the water quality implications would be
much more severe than described in the Draft EIS. EPA agrees
that the implications of the no-project option are rightfully
questionable because it is not known what action MWMC would take
by 1989 if no long-term sludge management solution is selected
now. It is unlikely, however, that the existing facilities at
the RWTP would be allowed to reach capacity and subsequently
cause a direct discharge of liquid sludge to surface waters.
Landfill Disposal
Two comments were made on the landfill disposal aspect of
the proposed project. The MWMC stated that the Draft EIS
description of the drainage system at Short Mountain was inac-
curate or at least unclear. Another commentor felt that the
existing leachate control system at the landfill was inadequate
and that sludge going to the landfill was poorly handled.
Overflows to the Willamette River were predicted.
The description of the drainage system at Short Mountain
Landfill should be revised to indicate that the permanent
ditches which discharge directly to Camas Swale Creek do not
receive runoff from the exposed, active landfill area. Drainage
from the active fill area is carried into the leachate lagoon.
A leachate collection drain exists at the southern edge of the
active landfill area.
The concern about the capacity and operation of the leach-
ate lagoon at the landfill should be allayed by actions taken by
the County in the summer of 1983. Problems with overtopping of
the lagoon had been identified during the wet winter of 1982-83
and subsequently DEQ requested improvements in the leachate
collection and irrigation systems. The lagoon capacity was
expanded in the summer of 1983 and is expected to have no
further capacity problems in the foreseeable future. The MWMC
preferred long-term sludge management plan calls for a cessation
of landfill disposal of sludge by 1989. The project, therefore,
would not contribute to leachate control problems at the land-
fill.
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Location of Facilities
Comments regarding the specific location of sludge manage-
ment facilities focused on the facilities planned at Site C.
Questions were raised about what part of Site C would be used
for sludge storage and whether the pipeline to Site C would have
any connection with the Agripac site. Others questioned the use
of Site C for sludge processing when septic tanks were not being
allowed in the area.
The specific location of facilities within Site C was shown
in Figures 2-5 and 2-8 in the Draft EIS. The Draft EIS analyzed
the southern portion of the site as part of the MWMC preferred
plan (Alternative 2) , while the northern portion was considered
as part of Alternative 1. MWMC has since indicated that while
the southern half of Site C may be preferable, it has not yet
selected a specific site and will eventually identify a 125-170
acre parcel for use from within the 295 acres contained within
Site C. If the facilities were laid out as shown in the Draft
EIS in Figures 2-5 and 2-8, sludge drying beds would be approxi-
mately 7,500 feet from the end of Mahlon Sweet Field crosswind
runway 3-21 if the northern half of the site were used, or about
8,000 feet from the runway if the southern half of the site were
used.
EPA's evaluation of the MWMC preferred plan was based on
the use of the southern half of Site C. If MWMC now wishes to
reconsider and leave open its options on the location of facili-
ties within the 295-acre parcel, EPA will not be able to reach a
decision on MWMC grant requests until a specific location is
selected. Also, the facilities plan engineers have indicated
that 125 acres are sufficient to contain the off-site facili-
ties; EPA's grant participation would therefore be limited to
this scope of project.
Site C is considered acceptable for sludge storage and
drying, given local drainage and groundwater conditions, because
all facilities will be lined to avoid transfer of sludge con-
stituents into the groundwater. The facilities will also be
surrounded by berms to avoid surface flooding. EPA is not aware
of specific grounds for septic tank system denial in the vicin-
ity of Site C. Septic tank and leach field systems, however,
require an aerated soil layer with adequate drainage conditions
to provide a natural filtering of nutrients and other materials
prior to leachate reaching groundwater. The seasonally high
groundwater and occasional coarse subsoils in the vicinity of
Site C would not allow the necessary soil filtering action to
occur year-round. This may have been the basis for denial of
septic tank systems. Site C facilities are not designed as a
waste disposal system, discharging to surrounding soils.
One commentor questioned whether there was any connection
between the sludge transport pipeline to Site C and the Agripac
34
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site. There is no planned connection between these two facili-
ties.
The Coburg Hills Site
One of the four locations for sludge facilities analyzed in
the Draft EIS was the Coburg Hills Site. This site is located
north of Eugene and east of Interstate 5, slightly over 1 mile
northeast of downtown Coburg. A number of persons living in or
representing the City of Coburg expressed concern over the use
of this site. This included City Council members, the water
commissioner, and an attorney representing the city and the
Muddy Creek Irrigation District. Opposition to the use of this
site was based on fears of groundwater contamination, odors,
property devaluation, visual detraction, and land use incom-
patibility. These are essentially the same concerns voiced over
use of Site C and the Prairie Road Site. One commentor voiced
support for the use of the Coburg Hills Site.
EPA has evaluated the use of the Coburg Hills Site
through preparation of the Draft EIS. The evaluation disclosed
that the pipeline route to the site would possibly impact two
archaeological sites located along the route (see page 166 of
the Draft EIS), and that use of the Coburg Hills site would not
provide a significant economic or environmental advantage over
the MWMC preferred Site C. EPA concluded, therefore, that the
Coburg Hills site would be dropped from further consideration
for grant funding purposes. Because the site will no longer be
pursued, questions regarding its analysis in the Draft EIS will
not be responded to in this Final EIS. EPA feels the analysis
contained in the Draft EIS was sufficient to warrant the re-
jection of this alternative site.
Land Use
Three land use issues were raised in review of the Draft
EIS. One commentor felt that the land use zoning consistency
issue associated with Site C had not been adequately resolved in
the Draft EIS. Two others felt that Site C should be reserved
for industrial uses, which would be more consistent with current
zoning and with the site's easy rail, air, and highway access.
A final concern was that use of the Coburg Hills Site would
violate a number of state land use planning goals.
The land use consistency issue at Site C was resolved, at
least on a local basis, when Lane County issued a conditional
use permit to MWMC in February 1984 for use of Site C. This
permit allows MWMC to use the site for sludge processing,
contingent on MWMC complying with a large number of conditions
placed on the permit. The County has determined that this use
is consistent with current land use and zoning policy for the
site.
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The County Comprehensive Plan for the area was recently
revised and adopted by the County. It has now been forwarded to
the Oregon Land Conservation and Development Commission (LCDC)
for approval. The revised plan designates the land north of
Awbrey Lane in the Site C area as agricultural and it is zoned
EFU (exclusive farm use) . LCDC is not expected to make a
decision on approval or denial of the revised Comprehensive Plan
until at least July.
The future use of the Site C area for industrial develop-
ment is apparently not being considered by the County, as it has
rezoned the area from M-3 (heavy industrial) to EFU (exclusive
farm use).
Regarding the land use consistency discussion for Coburg
Hills, EPA feels that the discussion on pages 160-161 and
163-164 of the Draft EIS was an accurate portrayal. Because the
Coburg Hills Site is no longer being considered as an off-site
location, further review of this issue has not been undertaken
in the Final EIS.
Project Design
Two persons who reviewed the Draft EIS made comments about
the design of the Eugene RWTP (now nearing completion) and the
design of the proposed facilities at Site C. The questions
about the RWTP design were related to hydraulic capacity of that
plant and the possible use of secondary clarifier space for
sludge storage. Regarding Site C, one commentor wondered if
transfer of sludge processing facilities from the RWTP site to
Site C would result in construction of duplicate facilities.
The question was also asked whether Site C design included
acreage for dedicated land disposal (OLD) of sludge. Finally,
one commentor asked what safeguards or guarantees for protection
of surface and groundwater were designed into the facilities at
Site C.
The questions about RWTP design are not directly related to
the impact analysis contained in the Draft EIS, but are more
appropriately facilities planning questions that should be
directed to MWMC. EPA investigated these questions briefly and
found that the decision to construct eight rather than ten
secondary clarifiers at the RWTP did not result in the freeing-
up of a significant amount of space. The design layout of the
plant with eight clarifiers does not leave sufficient space for
additional on-site sludge storage, in the opinion of the Sludge
Management Plan engineers, (Krugel pers. comm.). The question
of hydraulic capacity at the RWTP is based on a comment in the
Draft EIS regarding the need to expand wastewater treatment,
sludge thickening, and digestion capacity if on-site mechanical
dewatering were continued as a 20-year sludge management solu-
tion. Further investigations of this matter found that imple-
mentation of Alternative 3 would not create a hydraulic capacity
36
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problem at the RWTP; the continuous recycle of centrate from
sludge centrifuging on-site would eventually tax RWTP treatment
capacity in terms of BOD and suspended solids removal. The RWTP
20-year design did not anticipate a continuous loading of fine
suspended matter and BOD loading from centrifugating of sludge
(Krugel pers. comm.).
The transfer of centrifuge facilities from the RWTP site to
an off-site storage and drying location will not result in
significant duplication of facilities. The centrifuges and
their containment structure are designed to be mobile. The only
facilities that would be abandoned at the RWTP with transfer of
the centrifuges would be the centrifuge building foundation and
some buried piping.
The question of OLD of sludge at the off-site location was
addressed in an earlier section. No OLD will be allowed at the
off-site storage and drying location.
Numerous safeguards have been planned as part of the
off-site facilities in order to protect people from surface and
groundwater contamination. These have been described in detail
in the Draft EIS. Lining of storage lagoons, control and
recycle of drainage from drying beds, construction of perimeter
berms, and water quality monitoring are the major pollution
control features. EPA is further requiring that an impervious
seal be installed in all lagoons to prevent leaching of mate-
rials into the groundwater (see the Overview and Summary sec-
tion) . As was indicated in response to a question at the Draft
EIS public hearing, however, EPA cannot guarantee the perfor-
mance of each of these design safeguards. Proper construction
and operation of the facilities are critical to their proper
function.
Errata
This section lists minor changes to the text of the Draft
EIS that are needed to respond to comments. The page and
paragraph of the change is indicated, followed by the revised
text.
Page 165, second paragraph: ..."less than one percent of all
County prime farmland"... should be revised to read
..."less than one-tenth of one percent of all County prime
farmland"...
Page 142, first and last paragraphs: The statements that bald
eagle nest sites are located in the hills east of the
Coburg Hills Site should be revised to indicate that bald
eagles are known to winter in the vicinity of the Coburg
Hills Site.
37
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Page 40, last paragraph: The word "conditioned" should be
replaced by the word "thickened".
Page 84, third paragraph: The statement ..."composed of 6
inches of compacted clay"... should be revised to read
..."composed of a minimum of 6 inches of compacted clay"...
Page 78, Figure 3-5: The boundary shown on this figure as the
northern extent of the River Road and EWEB Water District
is in error and should be deleted.
Page 101, third paragraph: "(this does not include any of the
exposed, active landfill area)." should be added to the end
of the second sentence.
Other Comments and Questions
A number of the comments and questions received during
public review of the Draft EIS were not readily categorized into
the broad subject areas discussed on previous pages. This
section addresses those questions and comments. Each question
has been summarized and followed by a response.
Is the existing sludge lagoon at the Eugene RWTP compacted and
lined with clay? The RWTP sludge lagoon was lined with
clay and compacted prior to receiving sludge.
How can EPA allow violation of PL 92-500 and PL 95-217 with
implementation of the proposed project? EPA does antici-
pate violations of PL 92-500 or PL 95-217 if proposed water
protection safeguards are built into the project.
Was a public hearing held on the southern 125 acres of Site C?
The EIS public hearing conducted by EPA on December 6, 1983
considered the southern 125-acre portion of Site C. This
area was identified as the MWMC preferred location for
off-site facilities and was analyzed as part of Alterna-
tive 2 in the Draft EIS.
Who initiated consideration of the southern 125 acres of Site C
in the Draft EIS? In a meeting held in Portland, Oregon on
February 2, 1983, MWMC requested that the Site C location
be expanded to include the additional 125 acres.
Was there a public hearing on the Prairie Road Site? The
December 6, 1983 EPA hearing on the Draft EIS considered
the use of the Prairie Road Site.
Did EPA know that wells in the Site C area show 0 coliforms in
water quality monitoring? EPA found several sources of
data on local groundwater quality. Sweet, Edwards &
38
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Associates (1982) reported 0 coliforms in a number of local
wells.
Is EPA responsible for funding the proposed project and also for
protecting the local environment? EPA is the principal
funding agency for the proposed sludge management plan,
through the grant program authorized by the Clean Water
Act. EPA is also responsible for assuring that environ-
mental impacts are considered in the grant funding program,
and adverse impacts are mitigated where possible.
Would a tertiary treatment plant at the RWTP site have resulted
in less risk from pathogens at the Site C or Prairie Road
sludge handling sites? When wastewater is treated beyond
what is typically referred to as secondary treatment, the
goal is usually to increase the removal of nutrients from
the wastewater (nitrogen and phosphorus compounds). This
can be accomplished in a variety of ways, but these ter-
tiary processes usually generate a larger volume of sludge
than do secondary processes. The numbers and types of
pathogens in the sludge are not necessarily reduced, but
their concentrations may decrease. It is unlikely that the
addition of tertiary treatment processes at the Eugene RWTP
would result in a significant change in the pathogen-
related health risk at the off-site sludge handling loca-
tion.
Is it too late to construct dewatering equipment at the RWTP
site? There is sufficient space at the RWTP site to
construct mechanical dewatering facilities for the 20-year
design load of sludge. MWMC and its engineers, however,
have indicated that there is not sufficient space to
construct sludge storage lagoons and air-drying facilities
for the 20-year design load of sludge. This is one reason
that off-site facilities have been sought by MWMC.
How much clay (in inches) is normally required to seal a sludge
storage lagoon such as tha,t suggested for Site C? How many
inches does the EIS indicate will be placed at Site C?
There is no specific requirement for the thickness of clay
liners in sludge storage lagoons in the State of Oregon.
These design decisions are made on a case-by-case basis.
The general design rule used by DEQ for sewage lagoons
(including sludge lagoons) is that permeability should not
exceed one fourth inch per day. More stringent require-
ments are possible. In the Draft EIS groundwater analysis,
the liner was considered to be a minimum of 6 inches of
compacted clay with a permeability rate less than one
fourth inch per day.
Did EPA know that Sludge Management Plan progress reports
indicate that dedicated land disposal of sludge is planned
at Site C or Prairie Road? EPA is aware that some OLD was
planned for the off-site location in the early stages of
39
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Sludge Management Plan development. EPA, however, does not
consider this solution appropriate, and it is not a part of
the MWMC preferred plan as reviewed in the Draft EIS.
If sludge will not be allowed at the Short Mountain Landfill
after 1989, will some other DLD site be identified and
approved by EPA after 1989? Under the MWMC preferred plan,
all sludge will be dried and go to agricultural reuse after
1989. No DLD is planned after 1989 and EPA will not be
considering authorization of a DLD site.
How will vibration from the adjacent railroad affect the clay
liner at Site C? Clay is naturally a resilient, flexible
material when it contains some moisture. Sludge lagoon
clay liners should not be damaged by vibration from the
railroad as long as they are not exposed to the open air
for extended periods, and thus allowed to dry. The design
of the sides of the lagoons should take into account the
possibility that vibration could encourage slumping along
steep slopes.
Although the EIS indicates there are no airports near the Coburg
Site, there are three private landing strips within 6,000
feet of the site. During review of the bird strike issue,
EPA identified the private landing strips in the vicinity
of the Coburg Site. The investigation found, however, that
the strips were infrequently used, and were never used by
turbojet aircraft. They were not considered a factor in
the bird strike issue.
Would not the off-site sludge facilities at Site C detract from
potential investors' first impressions of Eugene, if they
arrive via Mahlon Sweet Airport? If the off-site facil-
ities are located at Site C, they will not be highly
visible to travelers moving from the city to the airport.
They will obviously be visible from the air. It is also
possible that odors generated at the facility may occa-
sionally reach the airport area. The frequency of this
occurrence is expected to be quite low, however, unless the
facilities are poorly operated or maintained.
The Draft EIS inaccurately portrays the opponents of the MWMC
plan as primarily residents of the area between Eugene and
Junction City, while the supporters are from the farming
community. In truth, many of the opponents are also
farmers. EPA agrees that the description of those voicing
concern over the project is not all-inclusive. Many of
those persons living in the vicinity of Site C and Prairie
Road are from the farming community and are opposed to the
MWMC preferred plan.
40
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Literature Cited
Frank, F. J. 1973. Groundwater in the Eugene/Springfield area,
southern Willamette Valley, Oregon. U. S. Geological Survey
Water Supply Paper 2018. 65 pp.
Frank, F. J. and N. A. Johnson. 1970. Selected groundwater
data in the Eugene/Springfield area, southern Willamette
Valley, Oregon. Oregon State Engineer Groundwater Report No.
14. Salem, Oregon. 20 pp.
Sweet, Edwards & Associates. 1982. Agripac irrigation site
groundwater study; unpublished report for the Metropolitan
Wastewater Management Commission, Springfield, Oregon.
Personal Communications
Geotechnical Consultants, Inc. October 19, 1982. Unpublished
letter report from Charles Kendall to Steve Krugel of Brown
and Caldwell, Eugene, Oregon.
Hudzikiewicz, Joe. April 3, 1984. Planner, Lane County Plan-
ning Division, Eugene, Oregon. Telephone conversation.
Krugel, Steven. March 30, 1984. Engineer, Brown and Caldwell,
Eugene, Oregon. Telephone conversation.
Lowenkron, Larry. April 3, 1984. Regional Engineer, Oregon
Department of Environmental Quality, Salem, Oregon. Telephone
conversation.
Peroutka, Alan. April 4, 1984. Civil Engineer, Metropolitan
Wastewater Management Commission, Springfield, Oregon. Letter
(with attached groundwater data) to Michael Rushton of Jones &
Stokes Associates, Inc.
Thomas, Jack. March 26, 1984. Lane County Land Management
Division, Eugene, Oregon. Telephone conversation.
41
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mtd.
BOD
DEQ
OLD
EFU
EIS
EPA
FAA
FEMA
FNSI
LCOG
LCDC
LIM
mg/kg
MWMC
M-3
PCB
RRSC
RWTP
biochemical oxygen demand
Oregon Department of Environmental Quality
dedicated land disposal
exclusive farm use zone
Environmental Impact Statement
U. S. Environmental Protection Agency
U. S. Federal Aviation Administration
U. S. Federal Emergency Management Agency
Finding of No Significant Impact
Lane Council of Governments
Oregon Land Conservation and Development Commission
Land Inventorying and Monitoring Memorandum
milligrams per kilogram
Metropolitan Wastewater Management Commission
heavy industrial zone
poly-chlorinated biphenyl
River Road/Santa Clara
Regional Wastewater Treatment Plant
43
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0$
U. S. Environmental Protection Agency - Region 10
Richard Thiel - Chief, Environmental Evaluation Branch, Seattle,
Washington.
Daniel Steinborn - Chief, EIS and Energy Review Section,
Seattle, Washington.
Norma Young - Project Monitor, Environmental Evaluation Branch,
Seattle, Washington.
Jones & Stokes Associates, Inc.
Sacramento, California
Charles R. Hazel - President, Program Management.
Michael Rushton - Environmental Scientist, Project Manager, All
report sections other than economics.
Thomas Wegge - Environmental Specialist III, Economics.
45
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Appendix A
Letters of Comment
-------
Index of Comment Letters
Commentor Page
Barnes, Melva A-19
Brown and Caldwell A-29
Clinkscales, J. Kyle A-32
Cook, Mr. & Mrs. William A-34
Dooley, Robert A-36
Elliott, Gordon A-38
Engels, Joyce A-41
Engels, Larry A-42
Garrett, Ernest A-44
Humphrey, Howard A-48
Kendall, Donovan A-55
Klemp, Dan and Ann A-61
Lane Council of Governments A-13
Lund, Lois A-63
Lyon, Richard & Sadie A-65
Mase, Nathaniel D. A-66
Melamed, Jim A-67
Meltebeke, Bob A-88
Metropolitan Wastewater Management Commission A-14
Moyer, Lucille A-89
Neely, John Jr. A-90
Oregon Dept. of Fish and Wildlife A-10
Oregon State Executive Dept. A-ll
Oregon State Historic Preservation Office A-12
Schrenk, Harold & Lois A-110
Springfield Area Chamber of Commerce A-18
Swenson, Chester A-112
U. S. Dept. of Army, Corps of Engineers,
Portland District A-2
U. S. Dept. of Housing and Urban Development A-3
U. S. Dept. of the Interior, Office of the Secretary A-6
U. S. Dept. of Transportation, Federal Aviation
Administration A-7
U. S. Dept. of Transportation, Urban Mass Transit
Administration A-9
A-l
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DEPARTMENT OF THE ARMY
PORTLAND DISTRICT. CORPS OF ENGINEERS
P. O. BOX 2946
PORTLAND. OREGON 97708
December 20, 1983
Planning Division
(PL-NR-EQ)
Ms. Norma Young
M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Young:
We have reviewed the Draft Environmental Impact
Statement (DEIS) on the Metropolitan Wastewater
Management Commission Sludge Management Plan, and
have no comments.
Thank you for the opportunity to review this
document.
Sincerely,
Patrick/TJ. Keough, P.E.
Chief, Planning Division
r\\ •- '
U U
DEC 23 1983
L EVALUariON
BRANCH
A-2
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
SEATTLE REGIONAL OFFICE
ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
SEATTLE, WASHINGTON 98101
REGION X |N REPLY REFER TOl
DEC " 7 I983
Ms. Norman Young, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Ms. Young:
SUBJECT: Draft Environmental Impact Statement
Sludge Management Plan
Eugene-Springfield,Oregon
We have reviewed the draft statement submitted with your October
28, 1983 letter. The proposed action would not adversely impact any HUD
assisted projects, thus we find no objection to your preferred sludge
management plan.
Our Portland office has reviewed your statement in detail and they
have some suggestions which are attached for your consideration.
We thank you for the opportunity to review and comment on your
draft statement.
Sincerely,
y Tanino
"/Regional Environmental Officer, 10CE
DEC 9
ENVIRONMF"™ ""• '*•• '•"• - •*
A-3
AREA OFFICES
Portland, Oregon - Seattle, Washington - Anchorage, Alaska
-------
Aesthetics are addressed by landscaping and somewhat remote locations and
odors appear to be controlled by operating and maintenance features.
The report addresses significant environmental issues in a responsible
manner and appears to have minimal impact on residential uses and water
quality other than what is projected in the comprehensive plan.
I believe one typographical correction should be made on page 165 in the
second paragraph.
Prime farmland lost seems to be one-tenth of one percent rather than one
percent.
Equipment under the BPA power lines may need to be shielded from ice
forming and dropping from lines and from radiation and leakage. Appropriate
grounding of metal objects is necessary. Ground-fault interupters are also
recommended.
Thank you for the opportunity to comment.
A-4
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U.S. Department of Housing and uroan Development
Portland Area Office, Region X
Cascade Building
520 SW Sixth Avenue -_ _
Portland. Oregon 972oflFfVr;U;:^ ^^
*-"—' I '• j' - - I ' i
2 9 1983
MEMORANDUM j^:^Jtobert c- Scalla, Director, Regional CPO, IX
THROUGH: /^mfc^^ar^ef, 10.3S
FROM: Clifford T. Safranski, Environmental Clearance Officer,
10.3SE
SUBJECT: Draft Environmental Impact Statement - Sludge Management
Plan, Eugene/Springfield, Oregon
We have reviewed the subject EPA-10-OR-Eugene/Springfield - Lane-WNTN 83
Draft Environmental Impact Statement (DEIS) and concur with their treatment of
secondary impacts as they effect HUD programs.
We would, however, suggest the following:
Short Mountain Landfill
Definition of what actions would be undertaken if the monitoring wells
reflect a problem would be helpful.
Forge Main Routes
The statement that periodic pressure testing can determine leakage but
not the location of the leakage could be refined to alleviate concern.
Perhaps sequential closing of valves would permit pressure testing of
pipe segments in a manner that would isolate the leakage for locating it.
Agricultural Sites
Since flood-irrigation practices appear to be a problem perhaps trickle
irrigation or a more acceptable method may be introduced to owners of
effected sites to reduce erosion and control run-off.
Mitigation
The use of the treatment plant site which is on the edge of the 100 year
floodplain and the other sites which can effect creeks and drainage areas
appear to be addressed by use of berms, dikes and ditches and impervious
lining for lagoons and drying beds.
A-5
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United States Department of the Interior
OFFICE OF THE SECRETARY
PACIFIC NORTHWEST REGION
500 N.E. Mullnomah Street, Suite 1692, Portland, Oregon 97232
ER 83/1412
Environmental Protection Agency
Environmental Evaluation Branch
Attn: Norma Young M/S 443
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Young:
January 12, 1984
D(
FEB 3
ENVIRONMENTAL EVALUATION
BRANCH
The Department of the Interior has reviewed the Draft Environmental State-
ment (DES) for Sludge Management Plan, Eugene-Springfield, Lane County,
Oregon. We ask that the following comments be considered for the proposed
project.
Water Resources
The U.S. Geological Survey reports the following:
Page 84, Site C; It is indicated that "leaching would virtually cease"
in fall and winter because of a high water table that may, in places,
reach the ground surface (p. 97). However, we believe that ground-water
mounding beneath the area of infiltration would create a gradient for
the lateral movement of leachate and that leaching will still occur if
the rise in the water table results in saturation of the sludge.
Page 127, Sludge Disposal; We note that the Metropolitan Wastewater
Management Commission's guidelines require monitoring to water-supply
wells near sludge reuse sites. The environmental statement should ad-
dress what actions will be taken if the monitoring reveals significant
degradation of drinking water in those wells.
Thank you for the opportunity to review and comment on this DES.
Sincerely,
Charles S. Polityka
Regional Environmental Officer'
A-6
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U.S. Department
of Transportation
Federal Aviation
Administration
Northwest Mountain Region
Colorado. Idaho, Montana,
Oregon, Utah, Washington,
Wyoming
17900 Pacific Highway South
C-68966
Seattle, Washington 98168
December 16, 1983
Ms. Norma Young M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Ms. Young:
We have reviewed the draft EIS for the Eugene, Oregon Sludge Management Plan
and have the following comments: i?
a. Site C would be located less than 10,000 feet from Runway 3-21 at
Mahlon Sweet Field. Runway 3-21 is used by turbojet aircraft. FAA
Order 5200.5 establishes 10,000 feet as the distance within which the
facilities of the type proposed may be incompatible with safe flight
operations. The EIS agrees that the selection of the distances
specified in Order No. 5200.5 represents a reasonable determination of
the danger zone around an airport.
b. Given that sludge facilities within 10,000 feet of a turbojet runway
represents a reasonable determination of danger we cannot find
anything in the EIS analysis which would indicate that construction of
these facilities within this area would lessen this danger. Indeed,
the EIS agrees that waterfowl use on Site C or Prairie Road would
increase, albeit, slightly.
c. The above notwithstanding, should the proponents persist in
constructing these facilities within 10,000 feet of Runway 3-21 at
Mahlon Sweet Field the following mitigation actions should be taken:
(1) Support structures for a wire or screen system above the FSL's
should be designed and incorporated in the initial construction
of the facilities. If wires are used they would be installed on
10 foot centers over the entire lagoon. The height would be such
as to allow adequate facility maintenance. The actual
installation of the system could then be more economically
accomplished at a later date if it became necessary.
(2) A waterfowl monitoring study at the proposed FSL's would be
conducted for a period of one year following construction of the
facilities.
(3) Should the study so indicate, the following measures would then
be taken as appropriate. Aerators would be operated
continuously, day and night, to discourage waterfowl from feeding
during the fall, winter, and spring. The above described wire or
screen system would be installed if continuous aeration failed.
A-7
Edward Warren: First American Aloft
-------
Whatever decision is made regarding construction of these facilities,
it should be clearly understood that the Metropolitan Wastewater
Management Commission bears the responsibility for correcting any bird
hazard problems that are created as a result of this project, should
it be developed contrary to the guidelines described in FAA Order
5200.5.
cerely,
<7
George L. Buley
Manager, Planning and Programnfoag/Branch
cc:
Mr. Paul Burket
Mr. Bob Shelby
A-8
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US Department
of Transportation
Urban Mass
Transportation
Administration
Region X
Alaska. Idaho.
Oregon, Washington
91 5 Second Avenue
suite 3142
Seattle, WA 98174
November 2, 1983
Norma Young MS/443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Ms Young:
The Urban Mass Transportation Administration has no comments with respect
to the Environmental Impact Statement for the Sludge Management Plan for
the Metroplitan Wastewater Management Commission, Eugene-Springfield,
Oregon.
Thank you for the opportunity to comment.
arey Davis
Regional Administrator
A-9
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VICTOR ATIYEH
OOVEBHOB
Department of Fish and Wildlife
NORTHWEST REGION
3150 EAST MAIN STREET, SPRINGFIELD, OREGON 97477 PHONE 726-3515
December 1, 1983
Ms. Norma Young M/S443
U.S. Environmental Protection Agency
Region 10
1200 Sixth Avenue
Seattle, Washington 98101
RE: Draft EIS, Eugene-Springfield Sludge Management
Plan
Dear Ms. Young:
On page 142 of the Draft EIS I am quoted in two different
paragraphs (first and last) as saying there are several
bald eagle nest sites in the Coburg Hills area. This
information is erroneous. What I did say was there are
observations of bald eagles wintering and roosting in the
Coburg Hills area. I know of no nesting sites. Please
correct the final copy of the EIS to reflect this change.
Thank you,
Sincerely,
Brian T. Ferry
Asst. Dist. Wildl. Biologist
Lane District
BF/mw
cc: J. Fessler
DEC 5 1983
ENVIRONMENTAL EVALUATION
BRANCH
A-10
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VICTOR ATIY6H
oovEmo*
Executive Department
155 COTTAGE STREET NE., SALEM, OREGON 97310
February 21, 1984
Norma Young M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
SUBJECT: Sludge Management Plan
PNRS # OR840112-020-4
Thank you for submitting your draft Environmental Impact
Statement for State of Oregon review and comment.
Your draft was referred to the appropriate state agencies
for review. The State Historic Preservation Office offered
the enclosed comments which should be addressed in preparation
of the final Environmental Impact Statement.
We will expect to receive copies of the final statement as
required by Council of Environmental Quality Guidelines.
Sincerely,
INTERGOVERNMENTAL RELATIONS DIVISION
Dolores Streeter
Clearinghouse Coordinator
DS:bm
Enclosure
A-ll
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OREGON PROJECT NOTIFICATION AND REVIEW SYSTEM
STATE CLEARINGHOUSE
Intergovernmental Relations Division
155 Cottage St NE , Salem, Oregon, 97310
Phone Number: 373-3732
P N P. S S T A T F o F V I F '-/
Project *.;.-, . •" ' '. .. . " \.. .''. '•.'• " Return Date;
-m , 1*-*
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
If you cannot respond by the above return date, please
call to arrange an extension at least one week prior to the
review date.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project has no significant environmental impact.
The environmental impact is adequately described.
( ) We suggest thaf the following points be considered in the
preparation of a Final Environmental Impact Statement.
( ) No comment. c
«.
Remarks
n FOR FURTl-tfJ INFORMATION
Agency "• ' ' r" --'' 3y Pi'APF ^P'T^T :rUMT
A-12
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Lane Council of Governments
NORTH PLAZA LEVEL PSB/125 EAST EIGHTH AVENUE / EUGENE. OREGON 974O1 /TELEPHONE (5O3) 687-4283
December 15, 1983
Ms. Norma Young M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Ms. Young:
As its regular December 8, 1983 meeting, the Lane Council of Governments Board of
Directors discussed the Draft Environmental Impact Statement for the Metropolitan
Wastewater Management Commission Sludge Management Plan.
The Board of Directors voted unanimously to express concern over two aspects of
the Draft EIS. The first concern of the Board was about the relative lack of water
quality information for all three off-site sludge handling facilities. The Board
also expressed concern about the possible long-range impacts on soil and water
quality resulting from the application of sludge and the failure of the draft EIS
to address this.
If you have any questions, please feel free to contact me.
Sincerely,
'' ""'"'' '/' ; ' •-' '
/ John Replinger, Program Manager
Transportation and Energy
JR:jwcl
cc: Metro Wastewater Management Commission
"BRANCH
.
-i
A-13
SERVING CITIZENS OF LANE COUNTY FOR MORE THAN A QUARTER OF A CENTURY
-------
Metropolitan
fV/l
1V l
COMMISSION MEMBERS
Christine Larson—Springfield Councllperson
Gerald Rust—Une County Commissioner
Pat Hocken—Eugene Uy Representative
Betty Smith—Eugene Councllperson
Steve Allen—Springfield Uy Representative
Mark Westling—Eugene Uy Representative
Gary Wright—Une County Uy Representative
225 NORTH 5TH ST. — SPRINGFIELD CITY HALL — SPRINGFIELD, OREGON 97477 TELEPHONE (503) 747-4551
December 15, 1983
Ms. Norma Young, M/S 443
Environmental Evaluation Branch •»
Environmental Protection Agency *
1200 Sixth Avenue
Seattle, WA 98101
SUBJECT: COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR
EUGENE/SPRINGFIELD SLUDGE MANAGEMENT PLAN
In pages 42, 43 and 44 of the draft EIS for the Eugene/Springfield sludge
management plan there are references to the relocation of the preferred Site
C facilities to a location south of the position previously proposed in the
1980 Brown and Caldwell facilities plan. We would like to point out that
the Commission's official position on this subject is spelled out in a
resolution which was adopted by the Commission on October 27, 1983 (Resolution
No. 83-26; attached) which recognizes that the additional area identified
south of the original area at Site C may be a more desirable location for
the Phase II sludge management facilities. Thus, this area was included as
an alternative site for the sludge management system but was never designated
a preferred site. It is the Commission's preferred alternative to locate
the sludge management facilities within the approximately 295 acres identified
as Site C in Figure 2-6 of the draft EIS and to acquire the approximately
125-170 acres necessary from within this expanded identified parcel of land.
We would also like to pass along some comments received from the Lane County
Public Services Division concerning the information presented in pages 101
through 103 on the Short Mountain Landfill. They have pointed out that
contrary to Figure 3-11 in the EIS, that water generated on the site is
routed away from the active fill area and that the ditching shown in Figure
3-11 is actually outside of the landfill area so only uncontaminated water
is discharged to Camas Swale Creek. A subsurface leachate collection line
is maintained along the south edge of the active fill areas and this line
is designed to collect leachate from the fill areas and discharge into the
A-14
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Ms. Norma Young
December 15, 1983
Page Two
leachate lagoon. Lane County has expanded the size of the leachate lagoon
to assure that no discharge of leachate occurs. Lane County Public Services
Division has passed along to us the attached modified Figure 3-11 which they
feel more closely represents the actual patterns of drainage at the Short
Mountain Landfill.
Thank you for this opportunity to comment. We hope to have our consultant's
comments in shortly.
Very truly yours,
C
EDWARD BLACK
Environmental Affairs Supervisor
EB:AP:sh
cc: DC
BCS
Enclosure
A-15
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METROPOLITAN WASTEWATER MANAGEMENT COMMISSION
RESOLUTION NO. 83-26 (IN THE MATTER OF THE
(NECESSITY TO ACQUIRE
(SITE C)
WHEREAS, the Commission at its March 12, 1981 meeting unani-
mously adopted a motion approving action to acquire Site C as the
sludge management site.
WHEREAS, an additional site immediately south of Site C and
west of the Southern Pacific right-of-way may be a more desirable
location for the sludge management site.
WHEREAS, the draft Environment Impact Statement recognizes
both the additional site and Site C as a potential location for
the sludge management site.
WHEREAS, it is the desire of the Commission to reaffirm its
motion of March 12, 1981, and include the alternative site as an
alternative location for the sludge management site,
NOW, THEREFORE, BE IT RESOLVED BY THE METROPOLITAN WASTEWATER
MANAGEMENT COMMISSION:
1. That it is necessary for the Commission to acquire
approximately 125 to 170 acres for the sludge management site for
the permanent sludge management program.
2. That the Commission proceed with action to acquire the
approximately 125 to 170 acres for the sludge management site
from that property identified as Site C in the draft Environ-
mental Impact Statement consisting of approximately 295 acres and
located north of Awbrey Lane, south of Meadowview Road, east of
Highway 99, and west of, and adjacent to, the Southern Pacific
right-of-way.
ADOPTED BY THE METROPOLITAN WASTEWATER MANAGEMENT COMMISSION
of the Eugene-Springfield Metropolitan Area this ^T^day of
^«X>A->^> , 1983.
'President
ATTEST:
A-16
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a
COAST FORK
WILLAMETTE RIVER
FIGURE 3-11. SURFACE DRAINAGE FEATURES AT SHORT f
MOUNTAIN LANDFILL |
A-17 "
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spRiNGFieiD aRea CHameeR OF commeRce
223-H NORTH A STREET P.O. BOX 155 SPRINGFIELD. OREGON 97477 PHONE (503) 746-1651
December 19, 1983
Ms. Norma Young, M/S 443
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
SUBJECT: Draft Environmental Impact Statement on MWMC Sludge Management Plan,
Eugene/Springfield, OR
The Springfield Area Chamber of Commerce has gone on record supporting the
Metropolitan Wastewater Management Commission's (MWMC) preferred long-range
sludge plan calling for transportation of digested sludge frora the treatment
plant to Site C where the sludge will be stored, dried and used for agricultural
purposes.
The MWMC Sludge Management Plan is necessary for the strengthening and diversifi-
cation of the local economy.
Clearly, the regional sewage treatment plant cannot operate without a reliable
dependable sludge facility. We believe MWMC's sludge plan will prove to be
the best solution to our community's sludge management requirements.
Sincerely,
C. Robert Smith
Executive Vice President
21 1983 --'
GATEWAY TO THE MCKENZIE RIVER
A-18
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I Only One Law would be necessary - Thank God - the Golden Rule - "Do unto others as you
would havo them do unto $ou" What have the people of Site "C" or Prairie Rood or
people of Junction City done to tho city of Eugene or MWKC.
City of Eugene and MBMG-through their agents havo* if Site "C" or prairie Road is used
\ as storage of Eugene's sewage sludge which hao lead, lindano, andorin, methodic
, I chlorate, technical chlordane, toxiphine, PCB's 2-4-D, silver, copper, berium, *oron,'
J cadmium, chromium, selinium, mercury, arsenic, zinc, and othersj
Eugene/MWMC t
Violates the public Laws 92-500 and 95-21? confine pollutants so they won't contaminate -
placing heavy metals, toxic pollutants directly over the known domestic water supply
for Junction City and residents of Site "C" and Prairie Road site is in violation
of these laws.
Violation of EPA Law - not to create Bird Strike Hazard within 10,000 feet of Airport.
Southern Pacific Railroad line is 10,000 feet away from the Airport - all of Site
"C" is by EPA Law not lawful for sewage storage. Violation of EPA Law.
Violation of FAA 5200.5 Aircraft Safety Advioory -
placing sewage that attracts Bird - potential Bird Strike Hazard within 10,000 feet
Airport. If map presented by MWMC of the area is activated sludge would be located,,
as close as ^,000 feet approximately to Runway 21 which flies directly over Site "C
on take off and landings. Violation of Law I EPA - HB 3171* & FAA
Placing sewage on Site "C" or prairfe Road considered (by FAA as the same concern -
FAA believes it could cause Bird Strike Hazard and warned Eugene and MWMC not to
locate;;th> sewage on those sites! violation of LawJ HB 317^ & EPA & FAA
' " Lbcatlngj jthe Airport directly between Fern Ridge Lake - roosting for waterfowl,
and sefeagfe attracting disposal on Site "C" or Prairio Rood sites - violating the
DEC 19 $&k advisory 5200,5* By Eugeno owning the Airport to not eliminate such potential
for Bird Strike Hazard they would be putting themselves in non-compliance with
rNTAL^.d°Ar!yilfun
-------
What right do you have to operate outside the Law? How does Eugene have the right
to condemn property In the county, outdide their urban growth boundary, outside their
urban se»lce area, what law # allows that?
We have tried through letters, meetings to stop tho POLLUTION of our WATER and LAND
by Eugene's toxic, heavy metals, hospital infections sewage sludge, in response
we learned of Shirley Ditch project where Eugene injected high ammonia nitrate
injections into the aquifer in north Santa Clara area on April 12, 1979, not getting
the reading they wanted they doubled the ammonia nitrate injections on April 30, 1979.
On April 26, 1979 they introduced 440 million ESCHERICHIA Coli bacteria, opportunistic
strain intt the aquifer to check water flow. Was EPA aware of this action? Was
there other injections made in other areas? Was this the area where the 70 mg/1 nitrate
was reported by DEQ? Was that 70 mg/1 injected by Eugene? Could this be the back-
ground for the comment between Freeman and Million Pye when Freeman asked about
River Road/Santa Clara health - William Pye responded "OH. WE'LL BLOW EM RIGHT OUT
OF THE WATER"? Because we have been trying to bring to EPA attention and officials
of the government what we believe to be illegal acts against the people's water and
health by writing and sending information from their MWMC meetings, documents,
Brown & Calawell, CH2M Hill - did comment by KVAL-TV Skip Lindeman after apparently
conferring with William Pye - "He thinks the whole thing is going to far. 'He used
to think only residents were concerned about this. Now we have our hands full with
a whole bunch of crazies_."
If we are wrong Aor-trying to mako federal officials aware of crime against the
people's water, health, very lives, found in their own reports, meetings projects
funded by FEDERAL money - then I guess you would consider us crazy. We believed
Federal money was obtained to protect the water, not destroy ours. Public Law
92-500 and 95-217? Locating a toxic, Industrial heavy metals, hospital diseases,
over a known domestic water supply for junction City is a violation of law! Ours and
Junction City's SOLE SOURCE water supply. Wells have been tested and our water is
good. The information given out by MHMC ought to be questioned.
please see Legislative Bulletin page 2 - No 29/79 January 10, 1979
GAP SAYS OK TO SEPTICSt The General Accounting Office (GAO), in a report to
Congress, called septic systems, "environmentally sound, technologically feasible,
and cost effective" alternatives to costly sower and central treatment facilities,
The report concluded that, if properly constructed and operated, septic systems
* can be ao permanent as central treatment facilities;
* are often more ecologically sound than sewers and central facilities\ andj
* can provide a high degree of wastcwater treatment, as good or better than
effluent from central treatnent plants.
Also checkANorth Carolina Septage Study - which infers that there is no proof
that properly working septic tanks systems put out any disease causing pathogens.
yet North Carolina Septage study stated that activated sludge from treatment plants
when put on land has caused endenic and epidemic conditions.
I believe MWMC has informed the federal government that they have so many farmers
wanting that sewage sludge they can't meet the demand for it. The farmers in the
Site "CH and prairie Road have signed petitions that they won't use sewage sludge
on their land, what farmers names do they have to get additional 10% funding for
as alternative and Innovative sewage use? Did putting sewage sludge on Marquess
land in Crepwell cause pollution of the neighboring wells? Was the lagoon
-------
They have criminally trespassed on our land where they had no right to be. Through
the Eminent Domain Law they took us to Circuit court and Oregon Supremo Court condenning
the east 25 feet of our property for an easement to put in the Agripac Pipeline. The
east 25 feet of our poropty is on tho east side of prairie Road. Where did they put
the Agripac pipeline? They put it on the west side of Prairie Road - not where they
took us to court overt fiur attorney notified them before they started digging that
they were in error. We told the workmen if they kept on digging they would be committing
Criminal Trespass. They went right ahead. It is recorded on Video Tape of the Criminal
Trespass I Now in front of all these wittnesses - I order you to get this illegal Agripac
line off our Proparty right NOW! You have clearly demonstrated to us for the last five
years you have no regard for the Law or for Human Rights. It is my belief that "God"
and a lot of others know why Eugene .Oregon is called "Little Russia" by other parts of
the country - and no business or people would ever locate here - the way the people who
get in your way are treated! Human rights are a Joke to you!
As the Senator of Idaho said tn the Register Guard - "There has been more people killed
over water than over women or horses".
For tho same or less money all the sludge and Industrial wastewater (all toxics) could
have been taken care of at the treatnent plant. When CH2M Hill estimated to build a
third stage treatment plant with tertiary treatment for $6? MILLION. Brown & Caldwell
built a second stage treatment plant without tertiary treatment, without River Road/
Santo Clara Intercoptoro, without 2 secondary clarifiers, without recycle loads, without
an effluent pump station (that were included in CH2M Hill bid). Those items removed
by Lane County tax values, CH2M Hill estimate totaled about $29 million REMOVED. Brown
and Caldwell building that second stage treatment plant for $104 MILLION. Why did you
pay twice as much not to get third stage treatment?
Since you didn't build alternative plants that were offered to further treat the sewage
and make by-products, proved equipment by Judco dried sewage sludge to 5% to send for
proof it would burn without being lost in uptake. Also in process of combining with
proven equipment that incinerates sewage after that % drying had taken place. It was
found that drying by that systen to $Q% it could be burned apparently with solid waste
thereby answering two nation-wide problems without loss to atmosphere - but return in
steam byproduct, I know I don't know technically the right words to descrbie it but
have tried to so that EPA will investigate the potential for nation-wide answer to solid
waste and sewag sludge. The way Brown & Caldwell and MWMC have the sewage sludge answered
is to take at this time WHAT - 3»500 acres out of food crop production to put sewage sludge
on to start out with - what amount needed for 20 years? Is the map in 208 Plan adjoining
area of Agripac Federally financed site containing 10,000 acres described for 20 years
needs of 49 MGD dewage plant Intended for use without the Public being made aware of it?
How many more laws are you going to let be broken before you ACT? to PROTECT the Environment
and the People?
Can you prove that Bill Larson's mother's cancer wasn't caused by sewage, heavy metals
contamination of their well? Can you prove that Bill Larson's death by cancer wasn't
caused by sewage, heavy metals contamination of their well? It appears that the report
of Gary fflewis prothero Thesis showed heavy metals concentrations - zinc reported 4400 when
limit is 2000. William Pye says there is no heavy metal to worry about. How does Cadmium
given by Gary Lewis prothero Thesis as 11 — Cadmium given by Brown & Caldwell or MWMC
on Marquess settago report as 16 PPM - correspond to anount that can be put on land and when
it would reach life use of the site? By CBE report - Illinois - Cadmium is a tumor producing
substance, crosses placenta causing birth defects, causes chromosomal damage, when cadmium
is mixed with soil and leafy vegetables are raised in soil cadmium multiplies 978# in the
leafy vegetables, 2,41?$ in legumes (I believe that describes clearly leafy vegetables
were mentioned" by B&C not to grow on sludgeed soil).
',"*.-'- I
How many of the .ones receiving part of the $104 Million Federal funds and Local are going
tto use sewage sludge on their own land? The farmers when agreeing to take sewage sludge
on their lad sign an agreement that releases Eugene, MWMC from damages if the farmers land
is permanently destroyed, if someone becomes sick from contact with sewage on his land,
the farmer is the only one in danger of ^_"21 sued. Where is the farmer's protection?
who will stand up and be counted to prow,,,, 0unction City's and our water supply from
these fraudulent acts by Eugene and MWMC? Brown & Caldwell report says once It becomes
contaminated there is no way to correct it !I
-------
page 192 of EIS - 43 dry tons year initial use. Assuming Cadmium 7 mg/kg (B&C 1979)
Cadmium loading rate would be 0.7 kg/hat which is over the 0.5 kg/ha level set by EPA
for soils supporting leafy vegetables crops grown for human consumption. This loading
would result in exceedance of maximum cumulative Cadmium standards for agricultural land
within 8-33 years depending on soil pH., CEC. Annual nitrogen addition to the site
would exceed those recommended to control leaching. In summary DLD of sludge would limit
future agricultural use of the soils to nonfood chain crops on the site. As 16 ??M
mentionod In Marquess sludge report for his land - wouldn't this be excessive as much as
his land is expected to take of the sewage sludge. As Lowenkron inferred - could Marquess
property receive that sewage for over 50 years without cadmium build up in his land?
EIS report infers that microbial pathogens, heavy metals, toxics are not removed by the
new sewage treatment plant - infectionsJ virus, hospital diseases - did anyone check
with the Federal Government and the over 1,000 acres owned south of Pern Ridge Lake
for Bird reserve - not land over water wells for domestic use, not land used for leafy
vegetables, summer human food chain crops, dxiry cattle, if land disposal is the answer?
Why was cemented gravel pits at river site considered unsuitable, yet pits of sewage in
open gravel, sand, some areas of Site "G" and Praire Road have gravel to surface to
ground over a known domestic water supply where people all depend on their wells was
considered suitable sewage sludge disposal site?
As I was Informed by Norma Young - Agripac was funded for dual lines - then it changed,
how do we know that the dual 8* lines for Site "C" or or prairie Road or whereever won't
change? CH2M Kill estimated dual lines for Agripac and all for $3,678,000 - yet Brown &
Caldwell are putting in one line and all for $8,000,000 approximately - where is the
Value Engineering to that project or was CH2N Hill estimate considered false? If so,
then the evidence spoken to the public at public hearings has also been false.
Eugene has violated the citizens of Springfield's rights by denying them right to vote
on sewage rates - with this millions of dollars variance in Engineer estimates - who
can protect the people's rights? The $10.50 per month charge doesn't pay any on the
bonding does it? One paper found in the DEQ files showed River Road/Santa Clara residents
when added to the treatment plant would pay terrific costs - is that true?
As was reported by Pye pers comm in the EIS - was legislation Introduced or passed
that allows condemnation without show cause?
page 186 - accumulation of metals & toxic substances through forest food chain & transmission
of disease, such as Giardiasis & Salmonellasis, by game animals. - areas that might
eventually be used to grow human food crops would be of concern, (isn't it odd, some of
these concerns didn't seem to apply directly depositing these diseases & toxics into a
already existing known domestic water supply without miles of travel to penetrate that
water supply - how are laws allowed to be VIOLATED?) fcage 190 risk without further
disinfection -pasteurization, irradiation - reduction of pathogens - risk unacceptable
health risk - prevent use for production of food crops.
DLD - substitute for processing & reuse or disposal of sludge beyond initial digester
stage - pathogen levels are often high
page 19o DLD must be isolated - from any potentially useful groundwater aquifer & be
designed to prevent any possibility of contamination of surface water? DLD potential
contamination groundwater & surface. pH 6.5 or above could prevent significant migration
of pathogens, metals, toxic organixi to groundwater. (sewage reduces pH - DE3 waiver ing
6.5 pH requirement) Brown & Caldwell report stated migration be known so that no present
or future wells /be located in path of such a flow. DLD given as greatest pollution. See
June, 1979 Progress report stating dedicated land disposal adjacent to lagoon on permanent
sludge site??????? WHERE IS THE PROTECTION?
page 191 DLD -;38-40 dry ton year - 10 times agricultural application injecting DLD - result
20 times agricultural rate for nitrate - groundwater beneath DLD - result unsafe levels of
nitrate to downgradient drinking water supplies. Must be prevented by locating site where
leachate cannot travel to potentially useful groundwater aquifer.
A-22
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x Reading the EIS shows throughout the proof of the potential for contamination of Sole
£\ Source water supply for Junction City & us residents if Site "C" or Prairie Road is used.
/J Violation of our Civil Rights? - A septic tank request south of Site "C" and North of
Site "C" were denied - yet City of Eugene entering the county received approval of
large pits of sewage with toxic, radio-active, heavy metals, diseases from the hospitals
to put into the people's domestic water supply? When the city attorney was asked
if they would supply clean drinking water to these people after they contaminated their
water - the response was NO - that was TOO EXPENSIVEl
The article fron the newspaper says "There has been more people killed over water than
over women or horses'." - Senator of Idaho.
FAA was assured that sewage- would not be closer than 8,000 feet from the airport - that
would let a narrow strip be used 2,000 feet wide along the railroad tracks to comply
with the information given to F/LA.??
Bob Shelby was assured that sewage would be covered with water thereby birds would not
be attracted to it - what about the 60 to 80 acres of sewage drying beds?
FAA has sent letters to MWMC and Eugene advising not to locate the lagoons on Site "C"
or prairie Road - you are aware of it now if MWMC had not so informed you before by
MWMC or Eugene!
Site "C" as stated by Brown & Caldwell cannot take dedicated land disjgosal - air drying
only! Dedicated land disposal is greatest potential for groundwater pollution.
Progress Report No. 7, dated Jv>e 1, 1979 - page 2** - "Well stabilized sludge from
the bottom of the lagoons will: .be removed for disposal by means of a floating dredge.
Sludge will be pumped to adjacent air-drying beds for subsequent agricultural use,
citizen giveaway, or landfill disposal. The .rest will be disposed of in liquid form
on agricultural land or on dedicated land also adjacent to the storage lagoons."
2 dedicated land sites were dismissed near the river for flooding potential - yet MWMC
in their meeting minutes statement was made at the commission's option they could be
used?? Remembering Site "C" by Brown & Caldwell report cannot be dedicated land
disposal only air-drying. The public was never told of dedicated land disposal on "C"l!
I believe FALSE INFORMATION has been presented to the Federal Government to obtain
Federal Financing - which is a Violation of Law!
Did Eugene report to Federal Government for Federal financing that they owned the
land for the addition to the sewage plant? Did Eugene own Larson property, or do they
yet own it? As of September 13, 1982 Bill Larson filed suit against Eugene for the
return of his property and damages as Eugene had not paid Judge Allen's decree from
1981 to September 13, 1982. County records were changed to show Eugene the owner
in 1980 - as of 5-13-82 county records showed improvements of $35,000,000 on Bill
Larson's tax lot. As reported by TV Bill Larson was wringing money out of the city -
with l*£ years in court huge attorney fees, jury awarded him about 2/3 of the appraised
value as determined by Blinkhorn. I heard another property was condemned for public
use for $5,700, that was on county records as being valued now at $150,000.00 - yet
trying to sell it for $1*50,000.00, apparently not having used it for the condemned use??
That property was not condemned for sewage plant - but other public use.
Did Eugene report to the Federal government officials that the treament plant had been
in compliance with discharge permits and had no problem complying? DEQ file showed
repeated violations from 1969 to the date DEQ and Eugene agreed and signed agreement
admitting they would be in violations of discharge from 1977 to 1982 - was that a permit
or a violation. of law. Also November 1, 1982 when taking us to court to condemn for
Agripac pipeline and Agripac last piece of disposal site - Eugene was operating the
sewage plant without a discharge permit it had expired, if it was lawful, in 1982 August.
In court Eugene showed applying for the permit.
Our land in Site "C" or prairie Road site can not take more water than GOD gives us of
that clean water as rain. Our water wells have been tested and shown to be good water
for drinking, but that pollution Eugene plans will destroy all these people's water -
if you allow this pollution to take place are you also willing to deposit in the BANK
money to give these people to replace A- 2 3 wells if they become polluted or replace
their land if those heavy metals and toxins destroy farm land and it can no longer grow
their leafy vegetables or raise dairy cattle? if you aren't willing in writing to place
that money in the BANK for these people's protection - GOD is WITTNESS! '>..-/t~-
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Questions regarding Sewage proposed for Site "C" or prairie Road Site- as permanent
sludge management site j
1. How can the Violation of Public Law 92-500 and 95-21? be allowed when federal
money was obtained from the government to protect the water not polute it?
2. What did the digging of monitoring wells on the additional 125 acres show
as to depth of gravel from the surface of the ground?
3. When the lagoons are dug to 5 foot depth in the 125 acre area how many of them
would be in the groundwater level of water when dug?
4. Does the report by Brown & Caldwell acturately answer what happens when ground-
water is made to become contaminated on pages 3-2-/3-3/3-^ - as indicated in
Progress Reports discussing permanent sludge management dedicated land disposal
of the remaining sludge adjacent to the lagoons is intended, what are your
protections against this occuring?
5. How long is the sewage to be treated in digestors before being stored in lagoons
on Site "C"?
6. Was there a Public Hearing on the additional 125 acres added to the Site "C"
area?
7. Who initiated the additional 125 acres to be studied in the EPA EIS Draft
Environmental Statement?
8. Was there a public hearing on Prairie Road site?
9. What owners of Prairie Road site were contacted about soils samples being taken?
10. What are the results of the Cadmium level in the Eugene/Springfield sewage
sludge to be put on Site "C" or Prairie Road in lagoons?
11. Was Mercury or PCS, 2-4-T found in the Sewage sludge to be placed in lagoons
on Site "C" or any radio-active readings in the sewage sludge?
12. The movement of water flow in the Site "C" area was given by Brown & Caldwell
Krugel as 200 feet a year - how does that correspond to the testing of U40
Million Escherichia Coll bacteria injected into the aquifer on Apr 26, 1979
when observed flow was 20 feet in 3.5 hours?
13. How would you answer the difference in report by Brown & Caldwell as to Cadmium
reported in Eugene/Springfield sewer sludge as being tested to 5 - 10 PPM, when
sewage sludge from Eugene placed on Marquess farm under sludge agreement contained
testing results of 16 PPM - more than twice the amount reported being there in
Eugene sludge at that time; since that sewage sludge is intended to go on Site "C"?
I1*. Did EPA know that the drinking water wells that were tested in the area
that were in use reported 0 coliform?
15. Mr. Burd, am I correct in the letter written to me earlier that EPA is the
agency providing the funding and is responsible to see that no environmental
damage occurs on these projects - or did I misinterpret the letter?
16. Would a third stage treatment plant have made a less hazard of pathogens, mlcrobial
pathogens to be put on Site "C" or prairie Road?
17. Is North Carolina Septage Study accurate that if sewage sludge having been through
activated sludge process then land applied might cause endemic or epidemic conditions
might occur on Site "C" or Prairie Road - or can you provide a guarantee in writing
able to be backed up in court that it won't?
A-24
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18. What is the cost of dewater equipment for Site "C"?
19. What is the cost of dewater equipment for treatment plant site?
s
20. Since you have stated that it is more expensive to place the dewater equipment
at the sewage plant we have to know the cost differences - closer to the electrical
power and river if emergency overspill - why would it be more costly near power?
21. Was Mr. Pye's statement to MAC meeting accurate when stating it was too late
to build in the dewater equipment at the treatment plant it had been built
past that point?
9
22. If your answer is yes to that question^ it was said in March 1980 or 81 I believe -
when the option was presented in letter to cover Bird Strike hazard question as
alternative to dewater at treatment plant - how could it have been too late then
to build it in - and now it is possible? I further believe Mr. pye said the plans
to dewater at plant would have to have been made before June 1978 to do so.
23. How many persons from FAA by name were contacted about Bird Strike Hazard
potential by placing sewage sludge lagoons in Site "C" or Prairie Road sites?
2**. Since you have indicated that you will not make sure that mitigative measures
are in place - what assurances for Bird Strike Hazard prevention if sewage
attracts as FAA believes it will?
25. Are you, EPA, aware that FAA advised the City of Eugene and MWMC not to locate
sewage lagoons on Site "C" or Prairie Road?
26. What is the depth of groundwater to surface of ground at Site "C" area at this
time?
27. How much clay lining is usually required to seal a lagoon in inches as at
Site "C" or Prairie Road?
28. How many inches of clay are Indicated in the EIS report intended for the Site "C"
or Prairie Rod lagoons?
29. Is EPA aware that the Site "C" area is directly over a known domestic sole
source water supply for Junction City and residents of the area?
30. Does EPA law allow placement of sewage ludge with toxics, microbial pathogens,
diseases, mercury, cadmium, chromium, arsenic, selenium, PCS directly into a
known city's water well supply?
31. Can sewage sludge being put or planned to be put on Site "C"be considered
nonputrescible? Doesn't B&C report Indicate further treatment of sewage by
lagoon storage further stabilization?
32. Was EPA aware that FAA was informed that Site "C" sewage sludge was to be
nonputrescible - wouldn't that indicate that it would not decay or further
degrade?
33* What would make soils at Site "C" area that Eugene has stopped residents of
the area north and south of site refused a septic tank approval because it
would contaminate the groundwater - be able to be approved for lagoons dug
below the groundwater level with known toxic, pathogen, diseased, industrial
toxics possible radio-active (stipulation handed to us in court Nov 1, 1982)
be possible to be handled by this same soil?
Is EPA aware that any sewage «i«"»4 on Site "C" area would be in violation
of EPA law regarding Bird StiA-^Sizard potentfe. 1 - Southern Pacific railroad
at east side of site is 10,000 feet from airport by Brown & Caldwell report?
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: 35* Was EPA aware that the public had not been informed at public hearings
about the additional 125 acres being added to Site "C"?
36. Did EPA Seattle know that dedicated land disposal as indicated by Progress
Reports for permanent sludge management had not been brought to '' public
hearings on Site "C" or Prairie Road site?
37. Was it indicated that dedicated land disposal of sewage sludge from Eugene
and Springfield could not "be taken to Short Mountain landfill after 1989,
if so did that mean dedicated land disposal would be placed on permanent
sludge management site decided on by EPA?
*
38. AS I believe in the EIS concern for the game animals if sewage sludge with
pathogens were in place on forests, where is the concern for a known domestic
sole source water supply with those pathogens placed directly into the lagoons
into that depth of groundwater at first introduction of diseased, toxic sewage?
39. Would you pltase provide the names of the farmers wanting the sewage in the
area of Site "C" or Praire Road as indicated at the public hearing, and was
that list of farmers sufficient to obtain 10$ innovative and alternative funding?
40. Has any of the toxic, dioxin industrial discharge been placed into the sewage
sludge that is planned for Site "C"?
41. Is there any safe level of Cadmium and what effect does Cadmium overload
on a human body show up as?
42. Is there any connection points between the planned Site "C" sewage pipeline
and the already installed Agripac pipeline?
43. Evidence has been given in forming decision for Site "C" regarding a 70 mg/1
nitrate reading found south of Site "C" area - where is that location indicated
by DEQ - was it the cause for the moritorium of this area?
44. Was the location just asked about the sane location of Injections of high
ammonia nitrate loading to aquifer on April 12, 1979 and doubled dose Apr 30, 1979?
45. Was EPA Seattle aware that the Gary Lewis Prothero Thesis showed uptake of
heavy metals from Eugene Sewage sludge from treatment plant site - same sewage
intended for Site "C" or Prairie Road?
46. Drainage is indicated flowing from the prairie Road side of area through the
Site "C" site - won't the drainage be blocked by the construction of the lagoons
berms as Agripac site blocked drainage which caused Lane County road department
to be concerned for road bed softening?
47. Not only the blockage of normal drainage - but contamination introduced to that
Site "C" would be intermixed with the groundwater of area by the action of the
pumping of the railroad when washing machine action of the train tracks take
place - wouldn't that intermix the groundwater with contamination all directions
\J by that adgitation?
j v 48. AS our house has cracked windows and plaster from the railroad vibrations
J( >J\ how is that movement going to affect sewage lagoon clay lining?
H* \! **9» As per your EIS report - was the Indication that Site "C" lagoon lining would be
' '•-•! 6 inches of clay lining instead of 12 to 18 inches indicated at public hearings by
K Jp\ Krugel?
1 v 5°* What P*0*60*10118 ls EPA willing to put in writing for Junction City's water supply
. J '^ and ours of the residents living around Site "C" or Prairie Road and that our
^ land won't b« contaminated by thJA-26 nanent sludge management site storing Eugene-
"\ Springfield's industrial toxic, diseased pathogen sewage sludge with heavy metals
and that our water won't become contaminated by this sewage project?
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1. From your EIS report seems it's not OK to use sewer sludge as a soil, conditioner
• in the city except very limited use - but a farmer is supposed to put the- sewage on his
land repeatedly for years as a soil conditioner and EPA and MWMC thinks; its OK, is
that true?
(L 2. Do you believe city people can be sickened by effects of sludge where the farmers
wont? Most city property is not used to raise leafy vegetables and summer vegetables
such as a farmers land is expected to do. What do you believe will be the total amount
of land required to take out of human food production to use it for a sewage disposal
to handle all of Eugene's sewage needs for the next 20 years - the TOTAL ACEHAGE?
(7_ 3. In EIS mention was made where city users of sewage leaching of sludge constituents
into the groundwater - but city has piped water supply no potential for contamination
of their drinking water. What about the farmer's family water supply with sewage
leaching into their only source of water? What protection have you written down to
protect the farmer's water or land or health?
C ^. Is Site "C" the only site that was notified by the county for a public hearing
on conditional use? Was Goburg Site considered for a conditional use? Was Prairie
Road Site considered for a conditional use?
A-2 7
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1. What other alternative has the EFA been presented by the MWMC or Eugene to
study or consider other than composting? Were any other alternatives ever mentioned
that had been presented to William Pye to be considered in sewage sludge treatment?
2. Statements have been made of energy recovery - please explain - if only 11# of
plants energy can be reclaimed out of the methane produced? Wasn't it told to the
public that the Brown & Caldwell new idea of activated sludge - would take 1/2 the
energy that the trickling filters took? Why the extreme amount of electricial
energy demanded by this Brown & Caldwell plant now that it is being built?
3. Industrial pretreatment was to remove the heavy metals and toxics wasn't it?
So that there would be no pollution discharge by 1985 - are you considering that by
putting that pollution of heavy metals on the farmers land and water you have met
1985 deadline? We asked if MWMC had checked with other towns that had pretreatment
programs and I believe the response was they hadn't. Has the pretreatment program
been implemented and if so, where is the heavy metals and toxics going now? Where
will they be going when sewage sludge is put on a permanent sludge location?
**. Have you used the initials so long you forgot what they stand for? They are to
protect the environment of other people besides the city of Eugene - the ones you
choose to dump oni
A-28
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BROWN AND CALDWELL
CONSULTING ENGINEERS
D. H CALDWELL. PE Chairman
T. V. LUTGE. PE Pfesidenl
E. F. MISCHE. PE Exec Vice Pros
0. P. MORRIS. PE Vice Pres
December 19, 1983
Environmental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101 13-112-82
Attention: Ms. Norma Young, M/S 443
DRAFT ENVIRONMENTAL IMPACT STATEMENT ON THE
METROPOLITAN WASTEWATER MANAGEMENT COMMISSION'S
SLUDGE MANAGEMENT PLAN
On behalf of our client, the Metropolitan Wastewater Management
Commission (MWMC), we have completed our review of the Draft
Environmental Impact Statement (DEIS) on the MWMC Sludge Management
Program. In addition to and in support of the comments we conveyed
to you in our meeting of September 22, 1983, the following comments
are offered:
1. On pages 9 and 154, the DEIS states that no airports are
within 10,000 feet of the Coburg site. It should be noted
that three private landing strips are within 6,000 feet of
the site, although they are used infrequently.
2. On pages 10, 12, 18, and 158, the DEIS states that Site C
is prime farmland. The soil types found on Site C include
Awbrey Silty Clay Loam (SCS 280 A, Capability Class IV w)
and Coburg Silty Clay Loam (SCS 270 A, Capability Class II w)
A small portion of the entire tract consists of Malabon
Silty Clay Loam.
Prior testimony at the Industrial Triangle public hearings
in December 1979 by Mike Stoltz of the Lane County Extension
Service indicated the tract must be farmed as Class IV wet
lands because of the combination of soils found on the
tract. Thus, in reality the property is hardly prime
farmland, although it is comprised of Class II soil in
part.
Although Coburg Silty Clay Loam is listed as prime farmland,
the working paper on agricultural lands recognizes that
some soils which would otherwise qualify as prime farmland
BROWN AND CALDWELL
P.O. BOX 11680 EUGENE, OREGON 97440
2300 OAKMONT WAY SUITE 100 EUGENE, OREGON 97401 (503) 686-9915
ATLANTA i' DALLAS-FT. WORTH i .DENVER; EUGENE: , PASADENA. SACRAMENTO ; SEATTLE: TUCSON: WALNUT CREEK! ; WESTWOOD
A-29
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Environmental Protection Agency
December 19, 1983
Page two
may be excluded as prime farmland when there is inadequate
drainage. (Working Paper; Agricultural Lands, Lane
Council of Governments Research Division, November 1981,
pages 10-11.) Thus, it is not unreasonable to exclude this
property from the inventory of prime farmland, because its
mix of soils dictates that it be farmed as if it all were
poorly drained.
3. On pages 13 and 114, the DEIS states that with dewatered
sludge there is a lower chance of metal contamination than
with air-dried sludge. We believe this is untrue. Although
application rates are lower with dewatered sludge because
it has a higher nitrogen content, the sludge is spread over
more land and the same mass of metals is applied.
4. The summary of Alternative 3 on pages 13 and 14, as well as
later discussions in the text, does not mention the land
resource impact of using up the landfill sooner. We
believe the DEIS also greatly underestimates energy use,
failing to account for energy used for dewatering chemical
production and for treating recycle loads.
5. On page ,15, the DEIS states that the impact of the "no
action " alternative on surface water is unknown. If it is
truly a "no action " alternative, it is clear that major
degradation of effluent quality would occur as a result of
inadequate sludge handling capability.
6. Page 19 does not mention that the use of the Coburg site
would require longer haul distances and probably would
require trucking through the town of Coburg.
7. On the bottom of page 40 the word "conditioned" should read
"thickened."
8. The discussion of the clay liner on page 84 should refer to
"a minimum of" 6 inches as the thickness of the clay liner.
9. On page 84, the DEIS states that ammonia-nitrogen moves
rapidly through the soil. We disagree. Ammonia-nitrogen
is fixed or adsorbed to clays and organic colloids in the
soil. This is the primary reason why little ammonia is
found in groundwater under septic tank drainfields. The
ammonia is retained in the soil until it is nitrified.
10. On pages 86, 95, and 111, it should be noted that since a
dual force main will be constructed, if a leak were detected
in one force main it could be taken out of service and the
other used until the leak is repaired.
P.O. BOX 11680 EUGENE, OREGON 97440
BROWN AND CALDWELL 2300 OAKMONT WAY SUITE 100 EUGENE, OREGON 97401 (503) 686-9915
ATLANTA; I DALLAS-FT. WORTH ! i DENVER: EUGENE PASADENA: SACRAMENTO: ; SEATTLE I : TUCSON I : WALNUT CREEK: WESTWOOD
A-30
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Environmental Protection Agency
December 19, 1983
Page three
11. Page 168 does not mention energy use for polymer production
and recycle treatment with the mechanical dewatering
alternatives, nor does it relate the large amount of energy
saved by replacement of commercially produced fertilizer
when sludge is used for agricultural purposes.
12. On page 188, the DEIS states that from the standpoint of
pathogens, use of composted sludge would be safer than
air-dried, liquid, or mechanically dewatered sludge. We
disagree. We have found that long-term storage of sludge
in a facultative sludge lagoon results in pathogen die-off
comparable to that found in composting.
We appreciate the opportunity to comment on the DEIS. Please call
me if you have any questions regarding these comments.
BROWN AND CALDWELL
Steven J. Krugel
Project Manager
SJKrdrc
cc: William V. Pye, MWMC
Arl Altman, BCS
P.O. BOX 11680 EUGENE, OREGON 97440
BROWN AND CALDWELL 2300 OAKMONT WAY SUITE 100 EUGENE, OREGON 97401 (503) 686-9915
ATLANTA! I DALLAS-FT. WORTH i i DENVER; • EUGENE, i PASADENA: SACRAMENTO, i SEATTLE I : TUCSON ! .' WALNUT CREEK; ) WESTWOOD
A-31
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A-37
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Eugene, Oregon
December 18, 1983
Norma Young M/S 443 &$>.•• «d
Environmental Evaluation Branch
Environmental Protection Agency """"
1200 Sixth Avenue
Seattle, Washington 98101
Comments re Environmental Impact Statement re Metropolitan Wastewater Management
Commission Sludge Management Plan Eugene-SpringfieId, Oregon
I think H. J. Buttner's sludge dryer hooked to the O'Connor combustion boiler
is by far the most practical and cost effective solution to our sludge disposal
problem at the Eugene-Springfield Metro plant. Buttner estimates 1/4 acre of land
will accomodate the units for the whole Metro area. (Eugene owns enough land at
the Metro plant site to double their treatment capacity) I've been told it will
produce roughly four times the amount of steam energy as it takes to dry the sludge
down to 50% moisture where it burns Oder tree and all the emissions therefrom are
way below Contra Costa County's (California) emission standards which are lower
than E.P.A.'s. I am told detailed information about it has been sent to you.
I'm anxiously awaiting Buttner's development of a smaller size model which I
can use for my Angwin, California shopping center and adjoining developable land
that at present has no public sewers. I've been interested in alternative sewer
systems since 1968 and this is the most practical solution I have found.
Whether Buttner's dryer-boiler is used or not at the Metro treatment plant
I believe the Avon Babb families's land and their Delta Sand & Gravel Co.'s pits
directly across Beltline Highway from the Metro treatment plant has many options
and advantages now and in the future not available at any other location that has
been proposed or about which I have knowledge.
I've been around this area about 65 years and been interested in development
since 1960 and attended almost all the M.W.M.C. and M.A.C. advisory commission
A-38
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meetings since their inception, and others before them, and other related meetings.
The Babb family have approximately 500 acres of level land (gravel pits, gravel
resource land, orchard and farm land) from BeItline Road north to the confluence of
the Willamette with the McKenzie Rivers, about 1^ mile north of Beltline Hwy. with
a dike and roadbed on top of it for about 3/4 miles. It is better protected from
a 100 year flood than the Metro treatment plant or the land on the east side of the
Willamette River.
Lee Babb has told me the pit adjoining Division Ave. and Beaver streets
fdirectly across from the Metro plant is about 85-90 feet deep and it is still
cemented even in the bottom and up the walls to within about 15-20 feet of the top
and it is about 99.9870 water tight where it is cemented. They have to use a power
shovel to dig it lease and then crush and wash it before it can be used. All"their
roughly 100.acres of gravel pits are about the same and are cemented. I think if a
bench was dug around the pit with an open trench in the top of the cemented layer
the surface .water could be directed around the pit and pumped if necessary into an
adjoining pit, lake or the river^
Large .holding reservoirs so close to the treatment plant could hold the flow
during a malfunction at the treatment plant and peak flows, and then be pumped back
across Beltline for treatment as desired.
I would like to see a Hercules, California type Solar aquaculture green house
type plant tried on the Babb property that could recycle most of the waste and be
pure enough for at least industrial reuse or to recharge the ground water. The fish
in the lagoon could also recycle food waste from the larger food processors, restaurants,
etc., in the area. The Babb property is at the Division St. exit from the Beltline
4-lane Highway about 4 miles from downtown Eugene. I have seen information from
knowledgeable engineers that Solar heat will work even north of our latitude at
Eugene in a plant of the Hercules type, contrary to what some less informed people say.
It is my belief that even the much more cost effective (capital cost and operation
and maintainence) overland flow type plant the WMWC engineers first recommended for
the Agripac plant could have been located on Babb's property with several miles
A-39
Page 2
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shorter pipeline and less damage and maintainence, not being subject to the
vibration from S.P. trains and trucks on the Northwest Expressway on each side
of the pipeline and also the projected parallel pipeline route to Site C or the
Prairie Road Sludge disposal sites MWMC prefers. Even the sludge disposal sites
would be more cost effective and environmentally safe at the Babb site. Even if
a 100 year flood washed out the dike it would be close to the river with much
swifter flowing water, much greater dilution factor, further from developed land,
and on mostly gravel resource land instead of good crop land. Any discharge to the
river at the north end of the Babb property at the confluence of the Willametter and
McKenzie rivers would give a lot better dilution of the discharge.
Babb's location is a choice commercial or industrial site if the buildings
were built on top? of concrete vaults above the 100 year flood plain. Even if the
dike should wash out the river wouldn't damage or move the large concrete tanks on
a cemented base full of liquid, sludge or anything else.
The view of the river nearby would be an attraction and the sand, gravel and
concrete for construction would be a very short haul. The land would then be
reclaimed and very valuable to compensate for any extra cost for the foundations
or supporting pillars in the concrete tank. Odors could be a lot less offensive
than those from the new Metro treatment plant across the road.
If you have any questions or would read more of my suggestions let me know.
There is a lot more I would like to say. I'm always told to be brief, and that
is extremely difficult for me.
Sincerely yours,
GORDON W. ELLIOTT
938 Jefferson Street
Eugene, OR 97402
Message phone 686-0905
Page 3
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/j. -
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JOYCE M. ENGELS
90564
RJGENE, OR 97402
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Norma Young M/S 443
Environmental Evaluation Branch
U. S. £. P. A.,
1200 Sixth Ave.,
Seattle, WA 93101
Dear Ms Young:
DEC. 14, 1933
RE: EIS per Eugene-Spring-
field-Lane County Metro-
politan Wastewater Com-
mission plans
I"would hope that the enclosed personal views per the MWMC plans will
be considered in the decision to be made as to funding, and"the choice
of site location. I was ill "at the time~"of the Dec. oth hearing at
Springfield, and unable"to prepare a statement in time to "be"read, vo-
cally. I appreciate the"timing of this"hearing, staged between Thanks-
giving~and Christmas, the worst possible time for most of us, but"'that
is expected when public input is not very desirous—especially when it
is negative in the majority.
I am a"resident,"living North of the "Prairie"Road" site directly, and
adversely affected by"any possible water-table change or contamination
from both it and"""Site C"—and even more so, due to the acquife'r flow
direction, by the under-construction "Agripac" site. The latter was
once"the farm of my grandfather, purchased by"him in 1900. I and my
father are both^retired, now, and w° only have"173 acres, but"it is
"home." Father"has resided most of his"life here, and I since 1936._
Having^farmed here, we both know all the nuances of farming, the topo-
graphy7 and th° ground and acquifer~fyater)assets and problems. In re-
cent y^ars, since~this plan first became public knowledge, I have been
involved withhseveral gfroppsopposing it. I still oppose it7 ~ Evon
more since, as~a director of the pioneer Luper (Irving) Cemetery"board,
I was, with the "unlcnown heirs" of three early settlers, condemned so
that MWMC could take"our deeded roadway, purchased over 100 years ago.
In_an action still deemed ""unusaljp*, "we" were included in the condemna-
tion of the properties owned by Donald and Joseph"Cersovski, and families.
The City of Sugane'did tfie job on us, as a representative of MWMC7 I .
might note that tfie"condemnation suit"wording"as to the REASON th«y had
to"take all of these properties ( some 9 parcels are involved ) was thai-
they had th° right (?)"to take it, and that they planned erecting a facil-
ity with wMch to process "agricultural" industrial AND SANITARY SSWAG^
wastes." At"the time of the 2nd of these suits, they introduced into
the "court a new "interpretation" of "what "S3WAG-&" WAS—including solid,
gaseous, and radioactive waste matter. This AFT3R acceptance by EPA &
D^Q hearing processes. Now, the plan and"facility use does not comply
in anytfiigg"but site"with wnat was considered by the so-called "protec-
tion agencies." Due to the" many changes and marginally legal actions,
I"finally was forced to hire a lawyer, thus this process is, ami has,
been a constant financial"drain."J When it was_illegal, or blocked by a
regulation"or statute, tfiey (Eugane"^ Lane"County DSpts., and MWMC) had
them changed or set aside. Now, tfiey have the power of "quick-take,"
and most of us have run out of money. It is ill advised"to try anS figll
your own tax moneys^ especially wfien the"agencies designed to prevent it
do'not address these irregularities. The EPA is among thosa whose actia||S
are a disservice to their meaning and objective. Non-action is include^
But—I digress As a lad I"workecl for the former owner of the two sitea
at £his location, during the Summers in harvest, anH in Winters"plowing|
levelling, and planting_. Thus, I and my father have an intimate know- J
le^ge of both soils,"problems, anH advantages."" I cleplore the lack"of
actual farming knowledge among the heads of agencies which have th^ pow*l
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to affect the very lives of those whose lands decisions are made or
modified upon.
_. —4 —I *_1 _J --*
Of the proposed site locations, I and all I*"know oppose all but"one of the
"alternatives.^ I^cannot say much about the "Coburg"Hills" site as it
was nev^r introduced puBlically until this BIS was r«quired." As"a matter
of fact^ neither was^the "Prairie Road" site, until FAA guidelines came
into tfie picture as per^distance, when one of the Advisory Council had
accepted a flip comment"by Steve Krugel, engineer with Brown and Cald-"*
well as" a useful consideration. Sirrce^_it has apparently^ come into tfie
running. This council"was, as was the 1st advisory council, dismissed
by MWMC--rather, MOST were,_wnen the^present MAC was formed, with a ma-
jority being City, or County employes or consultants, thus assuring"fdr
a time at least that no more objections to MWMC^s plans"would be faced,"
by having a majority at all times. I will^state for the^re-cord that the
MAC has, in tHe main, performed outstandingly well in formulating an in-
dustrial^waste prog rain. _Not that" it"" will ever be implemented, but it is
a good base upon which" to^validate^restrictions on industrial users of
the^system.^ _I have reservations and oppositions to all the OTH^R^plans
which arose^from MAC since...and before. (SXcuse the typing—the «e» has
come unsoldered.)
Alternative IV ("No Project) would be personally preferred,"but is an
obvious ploy, and therefore unacceptable. It is not my intention to
play games with~a problem as direct as this one is. Being one of those
directly affected by the actions of alternatives (phase two)"which are
of value, I cannot supply affirmation for any but Alternative III—and
base tfiis on the prior study done by a firm still used in various ways
and areas now by MWMC—CH 2 M ^Hillt Comparing these two studies, tHe
prior one having been""thrown out due to lack of"public "input," I see
too many variations between"the graphics and the technical input of the
studies to validate the later conclusions by Brown and CaldwallTs many
studies^ Tfie prior study"indicated that the draft (final) by MWMC has
been prepared"using altered facts and figures^ In plain language, too
many "sharp"pencils" have changed marginal"areas into acceptable ones,
and poor ones into "useful" onest "You have the copies, and^I submit
you are remiss in not calling these flagrant changes of data in order"1
to reach tfie conclusions that MWMC WANTS." It^is^unfortunate, but^true,
that if one^hires a consultant^?) —I~"use the term wi th" tongue-in-
cfieek,"as I"3o not o^ten agree~"with these^so-called "experts"—one can
get the answers requested..Tone way or another. But—to carry into the
heart of the matter: ~" I feel the fiis^is 'xactly what"it was intended-to
be, the result of hired "consultants"^to summarize the data^submitted,
with itfs impacts. "'Unfortuantely']' when you start^with misleading data,
your conclusions are bound to^be erroneou:§1 Let us^take~"the main area
of controversy: ^Agricultural'Use of Sewage Sludge""as fertilizer for
farm use, and the need to have it near the lands^where it will be util-
ized, if at all. Again, you have to BB a^farm^r^to know that_it cannot
work, nor will it EV^R, as :?anners~canaot"utilize anything that liw in
nitrogen^profitably, and Hu® to the"weather factors, and haste required,
cannot be expected to^accept it except on "call^" Then again, it^has
been said that by spreading it on grass"crops it wi],l not get into"the
food^chain. U submit to you that there Has been and will continue to
T>e use by farmers of grass straw as supplemental T&ed/hay —which can
ent£fr the food chain via both milk and meat^, i leei^that anyone"wh~cT~
now u§es tl}is, Qr Elans on uging it, noi only do,eg SQ out of greed. or_
for some ot^er hoped-for profit motive. Wh«n "sludge" WAS available
at the River Avenue^plant, meticulous records were kept. I studied thfm
for a two year span7 and the most ANY "farmer" took was a pickup load,
in contrast to statements by MWMC's manager, William V. Pye...those
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--or w°re, available to verify my statements, should you be astute*
enough~to check them. I am not sure. but"suspect tRe most recent
statements that "22 farmers" (Mr. Pyej" are interested in applying tHe
sludge may also be a fabrication. I"leave that up to you, as Mr. Pye
rarely opens himself up to public question now7 Now to facts and figures
—which are as strong AND as frequent as applies the drawbacks of this
"product." " ONS " "
Th.3 use of sewage sludge for"agricultural use,"or as fertilizer for other
areas of use, as timber,_^foresf, or nursery^use is not"recommended at this]
time, though it may be in future. One nurseryman (name on request) wHo^got
a small amount of-it to experiment with, found to his Hismay when mixed"
withTpotting s&il, and watered,"it became like solid c^m^nt. Just"one ex-
ample, I"grant you, but most are^afraid to use it, after seeing the reieas
they have^^o sign to_obtain it7
A. Farmers will not b* bothered with anything this time consuming and
low in needed nitrogen.^
B.__ Scientists, and agronomists, still have concerns about the~35ng term
hazards of sewage sludge, depending on"~itTs content and use. (gee Dr.
Darren Turner's data, W.S.U. soil scientist, Salem "Capitol"Press" of
wk" of 19-25 Augt, 1979; Oregon State Univ.*xt3nsion Service Special Bul-
letin #499 (page 24] and the"6omBined Studies of the Universities' of MD,
NJj, CONN, & MASS" (1977) for reservations and warnings about potential
hazards to public healtK.) These studies also note"that_there would be
needed"( for a two-stage (limit) application! per each"lo7000 persons,
45 acres ( to start,) and that_"furtHer^research is~needed."
C. Following this (B7)"l submit the statement made in the advisory
committee mating of Steve Krugei engineer for Brown and Caldwell, that
(June"lO, 1930) "W^ WILL N^D 3,000 acrss"as backup land" (^"agricultur-
al use/appiication^TO STA^T.) The proposed 203 plan for the^y%r 2040
regarding land uses and^needs by then is graphic in noting some~10jOOO
acres will be needed ( and is outlined) North of Beacon Drive West, and
an additional 1,900 acres"in the "Industrial Triangle"—thus taking from
farm and/or industrialize and tax-personal use-production this much...
at a time^when both Sug9ne and Lane County are "looking" (?)_for addition-
al lands^of 100 or more acres"to that"end. " This does_jnot make s°nse,
in the overall view..t.but then, sens6 is secondary as^motive^ in this pla
D. Th° major problem with this^"product" is it's ov^rabundance." Land-
fill dumping will have to^continu- in any approved alternative —perhaps
not by choicej but until better methods of handling are found, which ^Rs
"saf9^" The glants^of^ear-conformity in Oregon are"those in Salem and
Portland. They too have no adequat^ alternative._ Th°y simply produce more
sludge than they~have suitable agricultural lands"upon which to apply it.
Portland sugg^st^d barging it^up the"Columbia River to Morrow County, whict
perHaps solved TH3IR immediate problem, only to compound it in Morrow Co.
Salem is no better. Refer to "Sunday, Oregonian" July 13, 1980: "Cities
worrying"as_sludge piies"upt» (Portland and Saiem) 5""Reluctance of farmers
and growers"to use sludge; " and "Del Mgnte r°fuses crops growg on lands
where^sludg*? was applied."
£. "Obviously, if_this alt8rnative is expanded, it means either farmers"
or^"dedicated" lands will have^to be utilized. As of May, 1982, signature^
of 63_farmers, large and small, w^re obtained in areas surrounding th^s6
"alternative"_sites"nearby,_piedging_jt5at they would NOT apply it on any
°^ their 12,415 acres. " For obvious reason,Sj again.
FlDedicated lands become "white elephants" and a source of an answer,
but this^method^aEj in Sacramtnto, CA ( wt}ere agricultural us^ is banned )
is^non-productive and costly. §houid Oregon follow in ttjis restriction^
and there are those lobbying for that type of legislation, it would be, as
th^s6 facilities, a loss. Losses are not unknown^to Lane County, as^h^
Solid Wast- Facility"^ which is to "Be scrapped after years of controversy &
great losses„. d^KT the "plans" failed to pan outo
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_ ^
If th2 foregoing factors, all negative overall,^ affect such an in-
stallation, on*5 might ask^WHY they continue with it;? ^The answer is
simp!9, yet complex, as too many officials~are ^mbroil^d, along with
the off^r of too much money. As one former^MWMC number ( and EX-
County Commissioner ~) stated at the 19g£TLane County Fair "I don't
GIVS a Damn what they cto with the sludge7 so long as^they get it out
of -?ugene and Springfield. "" TRis is the_obvious reason for" carry ing
this fiasco~ab.ead, to remove the problem from the "Metro" a?ea and^put
it in^an area of low population. In other words, "Damn the residents^
as long as W& g^t^rid of tRe (visible} problem." And^that is just how
Ws sSe it- in, the main. _ Never mind iegallitj.es, change the laws if they
hinder us^ and the zoning regulations, if TH^Y slow us down. This th&y
have already accomplish-dj with not a ltttie"angry opposition. To sum
it up^the "product" is in overabundance^ the money was slow in coming,
so the^plant was "compacted" and some facilities for processing w^re cut
out— leaving a plant that cannot adequateiy^V^R hand!6 the sewage that
has b^en'projected^f which, by the way, is already over projections in
^
Springfield's plant, passing the 19#5 figures during an accident which
was measured by thQ D^Q — axceeding 19#5's projection now, what will it
ar? ) _ "
be NBXT year?
Now to some of our persona"! concerns: The attitude and the methods"by
whi€h MWMC^has reached the present point of getting the problems they "
have shifted over on~to US; lies, fabrications, violations for both the
SPA-and th« DEQ guidelines never acted upon, as^well as state laws...
and, in particular, one law which refuses anyone or any commercial firm
contaminating, "or planning to contaminate, any single-source supply of
water, which means US." Our gnly "access is^our present acquirer, and the
rain. Most of us^have shallow wells ( under 9$ feet ) in the farm, rur-
al, suburban, areas, and deep wells in th^ cities, as" Junction City's.
How"can the SPA oven CONSIDER a plan that will, "as th«W (AtiUC^ngineers
piqjectj^ contaminate ^northerly^wells?" Eealcage or seepage, or eyen
leaching, is^possibie from lagoons , an3 especially, drying beds, and
the scientists are ALlTconsistent in their views that the agricultural
use of sludge or sludge facilities are prone to health hazards in areas
of "HlSH YEARLY RAlftFALL." That^s us, againt^ (This y®ar we have"al-
ready exceeded 5 fee^ — only one year of three"to meet or nearly meet
records — -and this year IS the record in 90 years of measurements.)
I was not"at the Sis hearing, but^caught part of a statement by a_man
at ^Ehat hearing on TTV--in which Re said that (wording^may be inaccurate)
"the s^udy was in result of concerns^by the puBlic, and it enlarged^the
picture to focus on determination of "whicH -alternative would b^st
" ^
MAJORITY." If this IS the objective, and funding^will be made on
the"basis of the plans OTH% THAN ALT^-RJlATIV^ ill, I f«ei 3pA^n«eds to
take a good look'at it's^responsibilities0 After all, MOVING a problem
is not a valid^reagon to"be given Federal Funding, and only tUflds to
shift the burden^from one area to another, and solves NOTHING/ " How, in
all good consci§nee^can SPA fund^this fiasco? * in fact, considering the
application^ already mad? , do th^y actually comply with a validity that
prior_grants afforded? In Bother words, I would ask for a "refund "^if
what we have se^n is said by^MWMC to Bs a valid program. If^this can-
not be done, then go with th- "No Project," and prevent further losses.
TWO
As to "Hetermining" who is to gain, and who is to lose, (benefit) I am
not sure that I want to Ls? ANY GOVERNMENTAL JUR^AUCRACY make such a
dejjisipn for me. What efer J>ecame of our "fights" unde"r law? -This
eventually wi],l affect the environments, lives, an3 more Jor 30.000
people living from the planned facilities Sorth ttf5 Monrpe and Junction
City. To date, it^only a^THR^AT. The threat is R3AL, and if "M«tro"
wants to dump"their problems on US, Only YOU stand-in their way. WitRout
tfie FUNDS, they wm handl6 it as it SHOULD be handled, by and for them-
selves. A_51
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5.
t)-
0f/TV,Recently, th* HaAD of th9 EPA was queStioned on. matter^concerning
industrial waste stSrage problems. He stated that there was NO way
of protecting completely any such man-made system, and that there IS
no "fail-sHfe" laggons"" to fits knowledge."
A There is no present ne.Sd for "sludge" as an encl product.
B Landfills should be used"' and checked for any leaching.
C Adequate" and suitable areas for expansion were"found to be"easily
obtained in the CH 2 M Hill stufly ON TH3 SITS (p'resftftt RWTP) The later
study by Brown and Caldwell noted some area owner's did "not wish to sell"
their land. So how come WE get ^ofidemned ancl they 3k> NOT? We don't want
tS sell EITHER! Inasmuch as Slements of the planned facility, -as"the
centrifuges and cll'rifiers (tfiey brag about that "saving, *) have been re-
moved from the ^i&W* they have THAT land upon which to erect the facili-
ties they want" to foist on US. " " " ""
D" There are NO ^failsale" monitor processes. What^we^have seen, and •
have documented, are sludge drying beds overflowing^on"to"adjoining lands,
a~laclc of any lagoon sludge/liquia ( 1979 — after the wettest August on
record|-and three MONTHS after the last Sried sludge was taken" to^ the
landfill at Short Mtn., and the hauling equipment was"sold,"there"is no
question aBout^what 3 months of builH-up did — it pumped itself over^the
edge o? tfie lagoon via an £ inch pipe and pulsating motor, into the""
Willamette River? f D^Q said nothing.) "Finally, liquid sludge hauled to
the"" landfill was handled^ so "Badly that even DSQ had to admonish MWMG &
hav« it cleaned1 up. After" re ad ing about D^Q's actions and th*ir failure
in the"Deschutes County chemical dump, I would not TRUST them to monitor
MY water supply.
-
Last but not least, "the "Bird-Strike* Problem. I^will not elaborate on
the material included in the"BJs except to point; out tHat on the Sacramen-
^ "
to Study only 22 ^s^agulls^w^r^ noted in the entire area in all, and"that
only a PART of the study done in Corvallis By JBaftv«3aB is in elude d^ T^he main
^
point made , and NOT included was his statement ( also in a^news it^m in
th^ Junction City Times, 1 TKat: ''If^you're going to"have more birds,
then obviously you're mOre likely to have a ^ird strike." ^This after:
"--a sludge facility WOULD attract more birds, and more VAgI^TIES^of spe-
cies --- " at a lagoon thaQ woulcj any g^ass fie^ds. Ygu already §ust know
that Brown & Caldwell, MWMC.^and officials, including thos® at th^. 3ugene
Airport (Matron Sw?et Fild] w^i-e giv^n notic® by th« FAA's Chief of Air-
ports Planning Branch, Georg® L.^Buley, TWIG2-, and .by Robert Brown; FAA
Regional Director, ONCB that they fully expect hazards and strikes, and
r^ferring th@an to their guidelines. . .as to distanc®, from runways where
jet aircraft land and take off. MWMC says NO problem will occur, as it
plans only a "facultive" lagoon." This is hogwash — it cannot BS a"facul-
tiv«"lagoon when the plan includes continual dumping of raw sewage over1
the entire year. Living as I do"^ right down the "slot1* and seeing the
end-of- runway lights from my driveway, this scares me no end...an3 not" to
say any possible crew and passengers using tfie pattern. 5 airlines are
also concerned, and have so stated their objections to "Site C."
I regard" the Eis^to be"a "Monument to Waste." I and others have opposed
the system's^moving "Metro's^ problem^into flUR' backyard, as it was, for^
FOUR iSARS". ^BuWtaucrats, consultant^ lawyers^ an d^ contractors have en-
ricHed" themselves or justified their"existance oyer"this "goldmine." "We
them almost completeiy"take^the whole mine, "while W2 got tfie
"SHAFT," as in the SOng Jerry Reed sings.... We have fac^d condemnation,
endless and futile hearings, incompetent consultants, lying politicians,
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"*-.,-" - 6.
illegal or fraudulent^ testing, som^ of which^were h§zarclous,
using livq virus -without advising the residents ("Shirlsy^Ditch")
the continual haras sm^nt,"th° tension, and" he art ache , none of
which" we re or will ever b° address^d. ^Th* point of attack from
the beginning maintain*5 d^by th°J"Metro" officials and ^ugen^ in
particular, was, if damage occurecU "Sue U§." That has been dgn° ,
but to little avail. One who rqcRntly died of cancer of the liver^
claimed both h^ and his mother w°rs poison^d^by th° wat^r, as he
us°d a w-11 adjoining th*" drying b°ds on Riv^r Av^nu*5 wh^n^cond^^mn^d, 4-
was never, to my knowledge, fully compensated for tRe payments, and"
died short some $107000 of what Sugone owed Rim. He had already sp^nt
nearly that in lawyers fees. Another has spent about $£,000 so~far.
This is an area which Has~'no_t been addressed in the SIS, "But on« which
affects all of us. One neighbor was in tfiQ nursery business, and was_
also condemned (adjoineS th=< plant on River Ave. also^then^moved out
here, and now THIS property lies within 300 feet o?_the r^c^nt purchase.
by MWMC of 123 acr^s adjoining_j"Sit^"C" , so has been^DOUSLY injured^
All of us Hav^ s^^n our properties de value d_^with^ the"" advent of the
plans alone. None of us will eyer s^e^this^in justice remedied. ~"0ne
member of^MWMC brought this up, but the^others were not inter^sted^
I would feei this inequity, inasmuch as^non^ of us, benefit from this
and future damage s,_SHOULD be'compQnsated for this financially. _ VP5^
should NOT hav- to pay to have "Metrotstt problem" dumped on us so th^y
do not. Th^re ar*5 many ways this could be don and SHOULD bp done.
With but 55^ of a"heart left, I will doubtless die before the worst of
the Samage^is done^but hate it will happen, as happen it will should
it be funded"? I^feel^now that I did all I could, wasting £ y^ars of
my life, "in enclless hearings and meetings, ranging fronf^he regular
7 AS "eye openers" of MWMC to tRose set up as special^mee tings and
advertise^ 4 hours before in the papers. . .another illegal ( State )~"
action, designed to prohibit public input."" I pity the poor ratepayers
saddleo. with this fiasco for the next 60 years or more^ and MWMC has
not even included retirement of bonds^sold by the "Service District"
(in actuallity, the County'Commissioners) to date. Due to this and
the direction and" inequities , and just plain political^ramifications
anct/or possible legal responsibilities, our commissioners now state
th^y "want out." Already, "Springfield ratepayers and users have found
the cost too high, and rebelled.^
Those who oppose MWMC's plans^are degraded, with"t°rms ranging from
"crazies,1* "Paranoid,1* "hysterical1*, and all^the way to "stupid" and
"uninformed." yfi are none^of^tTigse, but suspect we WILL be paranoid
before this is^over. l"note
-------
SPRINGFIELD — The Metropoli-
tan Wastewater Management Commis-
sion has expanded its search for a per-
manent site for disposal of sludge from
the Eugene-Springfield regional sew-
age treatment plant
The commission two years ago des-
ignated an area north of Eugene
known as "Site C" as its preferred lo-
cation for the 170-acre facility. The
site would be used to dispose of solids
left from the sewage treatment proc-
ess.
However, public protests against
the location forced a federal environ-
mental impact study, which meant the
agency would be unable to complete
the facility before the new regional
plant goes into operation next year.
The delay caused the commission
to develop an interim sludge disposal
program using the county's Short
Mountain landfill near Creswell and '
various agricultural lands during dry
weather.
fin an action taken Differ a closed
discussion Thursday, the commission '
adopted a resolution designating an ad-
ditional 125 acres south and west of
"Site C" as a potential location for the
sludge disposal facility.J
The properties are located south of
Meadowview Road, north of Awbrey
Lane, east of Highway 99 and west of
the Southern Pacific railroad right of
way. , -••,
Project director Bill Pye said the
decision will afford an opportunity to
consider locating part of the facility
under Bonneville Power Administra
tion transmission lines, if the BPA
gives its approval.
Pye said bothJ'Site C" and the_ad-
125 acres have been judged
acceptable in the federal environmen-
tal impact study completed earlier this
year.
While Thursday's decision provides
290 acres in which to choose a loca-
' tion, Pye said, the agencyjaay.be able
to fit its sludge disposal facilities in as
little as 125 acres, if it is able to use
equipment it is acquiring for the inter-
im disposal program.
In another action earlier in Thurs-
day's meeting, the commission ap-
proved nearly $2.9 million in construc-
tion and equipment contracts, nearly
$1.8 million of them for sludge facili
ties and equipment to be used in the
Interim disposal program.
The largest contract for $1,320,000
for the construction of the Terry Street
pump station in west Eugene went to
Marion Construction Co. of Salem, the
lowest of seven bidders.
'^QfcKU-f^
Sludge site
still sought
by^agency
i
I page 15C r
n^nn-Friday. October 28.1983^
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A-54
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Site "C" PotentialSludge Management Area
I would like to voice ray concerns about Site "C" and the influence it will
»
have on the surrounding land, people and cities.
First, the topography of the land is of low elevation, starting with the
Enid Station Road for it is only 365 feet in elevation. Moving on to the
north we find Meadow View which has an elevation of only 350 feet. This
means that there is more standing water in the Winter and Spring on these
lands. Any use of these lands for sludge management sites would cause
pollution on the surface water and damage to the lands within its boundaries.
The numerous small intermittent streams which run through the area would be
polluted by any liquid sludge being transmitted into the surface waters. Most
of these small streams run toward Junction City. This would cause environmental
problems for the people who live north of the site "C". Everyone who had a
well would have water problems plus any birds and wildlife would suffer for
lack of suitable habitat, food and water.
Second, I feel the area is subject to general flooding. The latest information
from Federal Emergency Management Agency on FloodHazard dated February 10, 198l
shows parts of site "C" in special flood hazard area. See Exhibit I.
Third, the land was designated for agriculture use in 197^ by the Lane Council
of Governments in their comprehensive area-wide planning program. This land
falls into two categories, Class I - High Intensity Agriculture which is row
crops, berries and orchards and Class II - Medium Intensity Agriculture which
is small grains, grass crops, fall and winter pastures, some orchards, row
crops and berries. See Exhibit 2.
In closing, I cannot see land which in 197^ was designated for high and medium
intensity agriculture use, will be proposed as a potential sludge management
site. It is a direct contradiction of the many goals and ideals and I quote
from the Lane Council of Governments:
"Large areas of Class I agricultural soils within and bordering
the Eugene-Springfield Metronol i.tan Area and in the lower
McKenzie River Valley ha^i A-55 converted to urban uses and no
longer available for farming. Demand for further urban develop-
ment on the county's best agricultural land is certain to continue
-------
in the future* However, this demand must be weighed against the
importance of retaining the agricultural land for food production
and open space."
Then is the land which is to be site "G" sludge management area is to be
taken out of agricultural use the governmental system which made these
policies have failed to make clear and unbiased policies and failed to
serve the people of this county.
A-56
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I
>'/
•. i
J\
I
; rnfflf*
PACIFIC R
I
I
ONE A
. V
APPROXIMATE SCALE
2000
7000 FEET
NATIONAL FLOOD INSURANCE PROGRAM
FHBM
FLOOD HAZARD BOUNDARY MAP
LANE
COUNTY,
OREGON
UNINCORPORATED AREA
PANEL 13 OF 33
(SEE MAP IN Of X (•ORf'AMLSNOtPH'NTtC
COMMUNITY-PANEL NUMBER
415591 0013 B
MAP REVISED:
FEBRUARY 10, 1981
federal emergency management agency
federal insurance administration
A-57
*
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uf
KEY TO MAP
SPECIAL FLOOD HAZARD
AREA
ZONE A
Nole These maps may not include all Special Flood Hazard
Areas in the community After a more detailed study, the
Special Flood Hazard Areas shown on these maps may be
modified, and other areas added
TO DETERMINE IF FLOOD INSURANCE IS AVAILABLE IN
THIS COMMUNITY. CONTACT YOUR INSURANCE AGENT.
OR CALL THE NATIONAL FLOOD INSURANCE PROGRAM.
AT (8001 638-6620. OR (8001 424-8872
February 10. 1981 Panel Revised To Reflect FEMA Title Block. -
-------
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A-59
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*
: AGRICULTURE
X
Uj
I
m
o
K PEOPLE, 1970
CUSS I HIGH INTENSITY AGRICULTURE: ROM CROPS, BERRIES,
AND ORCHARDS
CLASS II MEDIUM INTENSITY AGRICULTURE: SMALL GRAINS. GRASS-
CROPS . FALL AND WINTER PASTURE, SOME ORCHARDS. ROW CROPS.
AND BERRIES '•
CLASS III LOU INTENSITY AGRICULTURES: PERENNIAL GRASS CROPS,
FALL PASTURE
CLASS IV VERY LOU INTENSITY AGRICULTURE: PASTURE LAND AND
INTERMITTENT FORESTRY '
• CATEGORIES ARt BASED ON THE DOMINANT CHARACTERISTICS OF
SOILS ASSOCIATIONS. NOT OH INDIVIDUAL SOIL TYPES
• FOR ADDITIONAL INFORMATION SEE "LAKE COUNTY SOILS ASSOCIATION
MAP UITH INTERPRETIVE GUIDES* LANE COUNTY 1971
OOUQIAI COUNTY
-------
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A-61
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A-62
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***
A-64
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Junction City, Oregon
December 6, 1983
Norma Young
M/S 443,1200 Sixth Ave,
Seattle Washington 98101
In relating to the impacts of the proposed sludge Management plan
for the Eugene-Springfield area, Oregon.
We are opposed to the location of sludge in the area North
of Eugene and South of Junction City along Prairie Road and
East of the Southern Pacfic Railroad. This area is subject to
flooding during the winter when rain fall is heavyy such as
this year. The runoff from the sludge will contaminate our
wells for drinking water.
Yours very truly,
Richard fo.& Sadie A. Lyon
91884 Prairie Road
Junction City, Ore. 97448
DEC 8 1983
ENVIRONMENTAL EVALUATION
BRANCH
A-65
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November 1, 1983
I have "been in "business in Springfield for 15 years
and I'm real disgusted with our MWMC management.
To me and many others we have really "been ripped off.
I spear headed a petition drive and received more than
enough signatures to put our sewer charge up to a vote of
the people but a county judge ruled against us.
The City of Springfield has forced their sewer services
upon us through the use of bancrofting funds which itself
has proved very questionable. The project itself in our
case was illegal, yet the Qity of Springfield and MWMC was
able to force their wishes upon us. I personally can point
out at least 300 senior citzens on fixed incomes that are
faced! with a foreclosure of their homes.
Why can't we have a complete investigation and tyring
to light many of the high pressure tactics that were used?
The wastewater plant and sewerage lagoon itself is a
public disgrace. Many small businesses within a 10 mile
radius of this monstrosity are symptomatically being
eliminated. How can these things happen in democracy?
A-66
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ATTORNEY
AT
LAW
JIMMELAMED
259 E. Fifth Avenue
Eugene, Oregon 97401
(503) 345-1456
MEDIATION
AND
ARBITRATION
December 6, 1983
Norma Young M/S 443
U.S.E.P.A., Region 10
1200 Sixth Avenue
Seattle, Washington 98101
Re: Metropolitan Wastewater Management Commission
Sludge Management Plan DEIS
Dear Ms. Young:
Here enclosed are Comments to the MWMC Sludge Management
Plan DEIS submitted on behalf of the City of Coburg, Oregon,
the Coburg Planning Commission, the Coburg Chamber of Commerce,
the 102 members of the Muddy Creeks Irrigation Project and
more than 60 individuals and businesses residing or located
in the greater Coburg area.
I trust that the Environmental Protection Agency will give
full consideration to these written comments along with the
oral presentation that I will be making this evening in
Springfield, Oregon.
Please feel free to call or write with any questions that
you may have.
Very truly yours,
JCM/ss
A-67
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COMMENTS TO DRAFT ENVIRONMENTAL IMPACT STATEMENT
METROPOLITAN WASTEWATER MANAGEMENT COMMISSION
SLUDGE MANAGEMENT PLAN
Submitted to the Environmental Protection Agency
December 6, 1983
A-68
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COMMENTS TO DRAFT ENVIRONMENTAL IMPACT STATEMENT
METROPOLITAN WASTEWATER MANAGEMENT COMMISSION
SLUDGE MANAGEMENT PLAN
I. INTRODUCTION
These Comments to the Metropolitan Wastewater Management
Commission Sludge Management Plan Draft Environmental Impact
Statement are submitted on behalf of the City of Coburg, the
Coburg Planning Commission, the Coburg Chamber of Commerce,
the 102 members of the Muddy Creeks Irrigation Project (listed
in Exhibit "A" hereto), and more than sixty individuals and
businesses residing or located in the greater Coburg area (listed
in Exhibit "B" hereto). A copy of a joint resolution of the
City of Coburg and the Coburg Planning Commission supporting
these Comments is attached hereto as Exhibit "C" and, by this
reference, incorporated herein. All of these parties express
their appreciation to EPA for this opportunity to provide mean-
ingful written comment on this proposed sludge management plan.
In brief, the individuals, businesses, associations and
governmental entities represented herein: (1) question and
challenge the analysis and assumptions which lies behind EPA's
selection of the DEIS "preferred alternative" sludge management
system; and (2) are united in their opposition to the establish-
ment of any proposed remote sludge management facility at the.
"Coburg Hills Site."
The fact that EPA has resurrected the "Coburg Hills Site"
for consideration in the DEIS, without due notice and after
this site has been firmly rejected by the Metropolitan Wastewater
Management Commission (hereinafter MWMC) in its comprehensive
1980 Sludge Management Program, can only be explained by EPA's
obligation to analyze a set of alternative sites in the EIS.
This resurrection of the "Coburg Hills Site" is improper and
fails to fulfill this statutory and regulatory obligation to
examine a reasonable range of alternative sites. This resur-
rection creates the dangerous possibility of EPA locating a
massive sewage facility not by reasoned choice, but, rather,
by unlawful default.
The DEIS also fails to thoroughly evaluate, as it must,
all reasonable technologies for managing Eugene and Springfield's
waste, including "state of the art" technologies that would
not require the development of any massive remote site. Further-
A-69
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more, the DEIS preferred alternative system has been selected
based upon the assumption that there will be a sustained agri-
cultural sludge reuse market. This assumption is not documented.
There are numerous additional reasons for EPA rejecting
the resurrected "Coburg Hills Site" as the location for any
MWMC remote sludge lagoon/drying beds facility. Among these
are the five reasons that MWMC's 1980 Sludge Management Program
did not even include the "Coburg Hills Site" in its final site
analysis:
1. Less favorable drying conditions—less sun, wind,
more rain than central valley.
2. On slope—high bed construction cost.
3. Force main 2 miles longer than Site C.
4. Away from Agricultural lands of minimum limitation
for sludge use.
5. Poor road access. Trucks must go through Coburg.
(MWMC Sludge Management Program, 1980, p. A-ll)
While MWMC did not even include the "Coburg Hills Site"
in its final analysis of five potential remote sludge facility.
sites, EPA has seen fit to resurrect this incompletely studied
alternative for its final analysis of only three potential
remote sludge facility sites. EPA has done this without adequate
notice or explanation. Nowhere in the DEIS does EPA directly
confront the factors that led MWMC to reject the "Coburg Hills
Site" as one unfit for final analysis, nor does EPA adequately
explain its failure to resurrect or develop other alternative
sites.
Having been resurrected, the danger exists that the "Coburg
Hills Site" will be selected by EPA by default. As the only
other two remote sites under consideration by EPA, "Site C"
and "Prairie Road," are literally just across the railroad
tracks from one another, the risk exists that both of those
sites could be rejected by EPA for a single reason. With the
"Coburg Hills Site" being the only other remote site considered
in the DEIS, the risk of the "Coburg Hills Site" being selected
by default, rather than reasoned choice, is substantial.
Furthermore, any selection of the "Coburg Hills Site" for
the proposed MWMC remote facility would violate state and local
land use law, particularly state land use goals for the preser-
vation of agriculatural land, the timely orderly and efficient
development of public facilities, energy conservation and urban-
ization. The DEIS also fails to adequately evaluate potential
DEIS Comments Page 2
A-70
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ground and surface water impacts at and around the "Coburg
Hills Site" and fails to address the true economic impacts
of this potential development on businesses in the Coburg area.
For these reasons and others discussed below, the above-
named parties are compelled to submit these Comments in oppos-
ition to EPA's designated preferred alternative sludge manage-
ment system and to the potential location of any proposed sewage
facility at the "Coburg Hills Site." As is discussed, the
establishment of any proposed sludge management facility at
the "Coburg Hills Site" would be both unreasonable and unlawful.
II. INADEQUATE NOTICE AND ALTERNATIVES
A. EPA's Notice of "Coburg Hills Site" Alternative Inadequate
EPA has failed to take required efforts to allow public
participation by those potentially affected by the establishment
of a sewage facility at the "Coburg Hills Site" in and before
the "Scoping" process for the EIS. As described in 40 CFR
6.400, EPA must "make diligent efforts to involve the public
in the environmental review process . . .." It is futher
required that "[a]s soon as practicable after the decision
to prepare an EIS and before the scoping process, the responsible
official shall send the notice of intent to interested and
affected members of the public . . .."
Despite this obligation to make "diligent efforts" and
to give the earliest possible notice to potentially affected
persons, the first time that those potentially affected by
the location of a sewage facility at the "Coburg Hills Site"
reasonably heard of its resurrection was when the DEIS was
delivered to their mailboxes in mid-November, 1983.
An examination of the November 17, 1982 Scoping Meeting
Mailing List for this project (attached hereto as Exhibit "D")
reveals that not a single person from the Coburg area was included,
The owner of the proposed "Coburg Hills Site" was not even
notified. Newspaper notices and the News Release to the scoping
meeting (also attached hereto as Exhibit "D") do not remedy
this situation. At best, this press release and these articles
indicate that the proposed facilities would be located "north
of Eugene." Truly, these newspaper articles are misleading.
For example, the Springfield News article of Thursday, November
11, 1982, indicates that the facility would be in the Santa
Clara area. The Eugene-Register Guard article of November
10, 1982, implies that the facility being considered would
be in the Mahlon Sweet Airport area. There was, thus, no reason-
DEIS Comments Page 3
A-71
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able, much less "diligent," notice to people in the Coburg
area that any "Coburg Hills Site" was being considered for
resurrection by EPA.
This failure to reasonably allow early input into the
EIS process by affected citizens in the Coburg area helps to
explain certain deficiencies in the DEIS. This notice failure
probably resulted from the reasonable initial conclusion by
EPA that the "Coburg Hills Site" would simply not be an alter-
native in the DEIS. Regardless, by subsequently including
the "Coburg Hills Site" in the DEIS, EPA has breached its public
participation and notice obligations.
B. EPA*s RANGE OF ALTERNATIVES IS NOT REASONABLE
As briefly described in the Introduction above, EPA has
also failed to include a reasonable range of alternative sites
and systems in the DEIS. The National Environmental Policy
Act requires a "detailed statement . . . on . . . alternatives
to the proposed action . . .." 42 U.S.C. 4332(C). In addition,
agencies are commanded to "[s]tudy, develop, and describe
appropriate alternatives to recommended courses of action in
any proposal which involves unresolved conflicts concerning
alternative uses of available resources." 42 U.S.C. 4332(E).
The duty to discuss alternatives has been described as
the "lynch pin" of the entire impact statement. Natural
Resources Defense Council v. Callaway. 524 F.2d 79, 92 (2d
Cir. 1975). An in-depth discussion of a reasonable range of
alternatives insures that the decisionmaker, as well as the
public, has before it all reasonable approaches to a project.
At the very least, the range of alternatives should be sufficient
to permit a reasoned choice. Brooks v. Coleman, 518 F. 2d
17, 19 (9th Cir. 1975).
The applicable Council on Environmental Quality regulations
also require a "rigorous exploration and objective evaluation
of the environmental impacts of all reasonable alternative
actions .... In each case, the analysis should be sufficiently
detailed to reveal the agency's comparative evaluation of the
environmental benefits, costs, and risks of the proposed action
and each reasonable alternative." 40 CFR 1500.8(a)(4). "If
the environmental statement fails to explain the basis for
its range of alternatives, or why other reasonable alternatives
were not considered, then it fails to meet the mandates of
NEPA." State of California v. Bergland. 483 F. Supp. 465,
488 (D.C. Cal. 1980).
DEIS Comments Page 4
A-72
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Despite this obligation for EPA to evaluate all
reasonable alternative sites, the agency has failed to adequately
explain its resurrection of the "Coburg Hills Site" to the
exclusion of other previously considered MVMC sites. EPA has
also failed to explain its failure to develop additional alter-
native sites for consideration that have never been considered
by MWMC. In short, EPA has not considered all reasonably avail-
able alternative sites for a proposed remote sludge management
facility in the DEIS.
The net result is that the DEIS only proposes three alter-
native remote sludge facility sites, with two of those sites,
"Site C" and "Prairie Road," only a "stone's throw" away from
one another. Thus created is the situation where a single factor
might eliminate both of these sites, with the "Coburg Hills
Site" being selected by default.
For example, when comparing "Site C" with the "Prairie
Road Site" concerning the "bird strike" issue, the FAA has
stated "obviously there would be no difference in that impact
between these two sites." (Letter to William Pye of MWMC from
Robert Brown of FAA, February 20, 1981). This possibility
of the "Coburg Hills Site" being selected not by reasoned choice,
but by default, because of a particular- problem with the two
other considered sites, illustrates the inadequacy of the range
of alternative sites presented in the DEIS.
EPA has also failed to consider all reasonable alternative
technologies in selecting the DEIS preferred alternative system.
For instance, EPA has failed to consider "state of .the art"
on-site dewatering systems such as the JUD-CO heated screw
dryer. (See Exhibit "E" hereto). Such technology is cabable
of reducing sludge water content as low as 5%. The resulting
dried sludge product can be used for either energy production
or agricultural application. This technology is in use at the
Terminal Island Sewage Plant in the Los Angelas area. Best
of all, utilization of such technology could be accomplished
on-site at the RTWP and eliminate the necessity for any remote
site facility. Other modern technologies, such as that in
San Diego where a private contractor hauls sewage away for
incineration at its plant, have also not been adequately
addressed in the DEIS.
III. EPA's PREFERRED SYSTEM IS BASED UPON UNKNOWN ASSUMPTIONS
EPA's selection of the DEIS preferred alternative
system, where sludge is piped off-site for storage in winter
and agricultural application in summer, is based upon the
DEIS Comments Page 5
A-73
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inadequately studied assumption that there will be sufficient
demand by farmers for sludge reuse through the year 2004.
The DEIS* discussion of this issue, on page 46, is limited
to the following:
(1) an estimate that 2,050 acres of cropland will
be needed annually to accomplish total reuse of the
sludge by the year 2000;
(2) MWMC had 490 acres in its 1982 reuse program;
(3) Specific locations for actual reuse have not
been identified; and
(4) 4,500 acres that meet DEQ requirements for sludge
reuse have been identified.
Missing from this discussion is an adequate analysis of
the assumption that there will be willing farmers to accept
sludge for reuse through the year 2004, the end of the planning
period. Thus, EPA's preferred system is dependent upon a con-
tinuous private market to accept the sludge, yet there is no
adequate analysis of long-term agricultural interest in filling
this need.
This is critical, because, if there is not a sustained
agricultural demand for the sludge, then, under the DEIS
preferred alternative system, greatly increased use of the
Short Mountain Landfill, as a backup depository, will be neces-
sary. This possibility has not been adequately considered
in EPA's selection of its preferred system. For instance,
sludge could accumulate beyond the capacity of the FSLs within
two years. Under EPA's preferred system, this would then require
disposal at the Short Mountain Landfill, including dispo.sal
during the wet winter months. Such wet weather disposal could
result in dangerous, contaminated runoff from the landfill
site. (MWMC Sludge Management Plan, 1980, p. 9-18).
Furthermore, the DEIS has failed to consider and discuss
the following situations identified by the 1980 MWMC Sludge
Management Plan, at page 5-21, as potentially . interrupting
market acceptance for sludge:
(1) Uncooperative relationship between the urban
and farming communities, stemming from an issue such
as field burning.
(2) Crop damage attributable to sludge, or the rumor
DEIS Comments Page 6
A-74
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of such damage.
(3) Toxic spills in the sludge.
(4) Reaching application limits for heavy metals.
(5) Emergence of a better product.
(6) Change in DEQ or EPA regulations.
These and other such forseeable occurances must be addressed
in the DEIS in selecting a sludge management system that is
dependent upon agricultural reuse. EPA's analysis must consider
the very real possibility of a severely limited agricultural
reuse market and the economic and environmental impacts of
virtually complete reliance on year-round landfilling at the
Short Mountain site. It would be unreasonable for EPA to finance
the construction of a 5 or 7 mile pipeline and remote site
facility without virtual complete assurance from those farmers
who might reuse sludge that they do, in fact, intend to do
so.
IV. THE ESTABLISHMENT OF ANY SEWAGE FACILITY AT THE "COBURG
HILLS SITE" IS INCONSISTANT WITH STATE LAND USE LAW
The establishment of the proposed remote sewage facility
at the "Coburg Hills Site" would be inconsistant with state
and local land use law. The DEIS's discussion of this issue
is inadequate, stating, at page 157, that "no definite conclusion
is made regarding conformance with local and state land use
law and policy." EPA's endorsement of a sludge management
system without a comprehensive determination of the respective
legality of the alternative sites for that system is irrational
and illegal. As the DEIS recognizes, at page 26, EPA is obli-
gated under 40 CFR 1506.2 to identify inconsistancies of an
action with state and local plans and laws. This deficit must
be remedied in the Final EIS. It is illegal and unreasonable
for EPA to endorse a sludge management system which it has
not determined, at least to a reasonable degree of certainty,
can be legally constructed.
A land use analysis of the potential establishment of the
proposed sludge management facilities at the "Coburg Hills
Site" follows and indicates that no such establishment can
be legally accomplished under state and local land use law.
DEIS Comments Page 7
A-75
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A. The Establishment of a Sludge Management Facility
at the "Coburg Hills Site" Would Violate the State
Agricultural Lands Goal
The establishment of the proposed remote sludge management
facility at the "Coburg Hills Site" would violate State Land
Use Goal #3: "To preserve and maintain agricultural lands."
This goal further states that:
Agricultural lands shall be preserved and maintained
for farm use, consistant with existant and future
needs for agricultural products, forest and open space.
These lands shall be inventoried and preserved by
adopting exclusive farm use zones pursuant to ORS
Chapter 215.
The "Implementation" section of the state Agricultural Lands
Goal further declares:
Non-farm uses permitted within farm use zones under
ORS 215.213(2) and (3) should be minimized to allow
for maximum agricultural productivity.
The "Coburg Hills Site" is currently zoned for exclusive
farm use and is slated to also receive this protective designa-
tion in the impending Lane County Comprehensive Plan. Land
within an exclusive farm use zone "shall be used exclusively
for farm use except as otherwise provided in ORS 215.213."
ORS 215.203. The Goal 2 Exception Process, as described in
OAR 660-04-000, establishes how land identified as agricultural
land may be zoned for other than exclusive farm use. OAR 660-
05-010(5). Thus, any use of the "Coburg Hills Site" for any
sewage management facility, notwithstading the non-farm uses
permissible under ORS 215.213, would require an "Exception"
to the state Agricultural Lands Goal. This necessity for an
Exception to Goal 3 for any remote facility located on EFU
land has been recognized by a member of the Lane County Planning
Department. (MWMC Advisory Committee Minutes, February 11,
1981, p. 6).
Any "Exception" to the state Agricultural Lands Goal for
the "Coburg Hills Site" would need to be supported by "compel-
ling reasons and facts," OAR 660-04-000, including an explanation
why it is "not possible to apply the Goal to the particular
properties or situations." OAR 660-04-020(1). This analysis
would also need to include consideration of alternative sites
and an analysis of why the proposed use cannot be located on
non-resource land that would not require an exception. OAR
660-04-020(2)(b)(A)(i). For the reasons discussed above, the
DEIS1 restricted consideration of alternative sites certainly
DEIS Comments Page 8
A-76
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could not serve as the basis for an Exception to Goal 3.
It is extremely doubtful that an Exception to the Agricultural
Lands Goal could be obtained so as to establish a sewage manage-
ment facility at the "Coburg Hills Site." Perhaps the greatest
reason for this is the reasonable and MWMC recommended avail-
ability of "Site C," which is zoned for industrial use. There
is no "Industrial Lands" or other state land use goal requiring
an Exception to establish a remote sewage facility at "Site
C." Even if "Site C" were determined to be unfit for the proposed
remote sewage facility, a far more searching inquiry of alter-
native non-agricultural sites than that presented in the DEIS
would be necessary to establish the basis for any Exception
to the state Agricultural Lands Goal for the "Coburg Hills
Site."
B. The Establishment of a Sewage Management Facility
at the "Coburg Hills Site" Would Violate the State
Public Facilities and Services Lane Use Goal
The establishment of any sewage Management Facility at
the "Coburg Hills Site" would also violate State Land Use Goal
#11: "To plan and develop a timely, orderly and efficient
arrangement of public facilities and services to serve as a
framework for urban and rural development." This goal goes
on to state that:
Urban and rural development shall be guided and
supported by types and levels of urban and rural ,
services approprite for, but limited to, the needs
and requirements of the urban, urbanizable and rural
areas to be served.
The Guidelines to this goal include:
1. Plans providing for public facilities and services
should be coordinated with plans for designation of
urban boundaries, urbanizable land, rural uses and for
the transition of rural land to urban uses; and
2. Public facilities and services for rural areas
should be provided at levels appropriate for rural
use only and should not support urban uses.
As is further discussed below concerning the excessive
costs of locating any sewage facility at the "Coburg Hills
Site" and the inconsistancy of doing so with the State Energy
Conservation and Urbanization Goals, the establishment of any
DEIS Comments Page 9
A-77
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Coburg Hills facility would not be "timely, orderly and efficient."
The fact that the proposed system is not planned for implement-
ation until 1989 is reason for EPA to take a patient approach
to this project to ensure that the best practicable technology
is implemented. This goal requires that any possibility of
centralizing all facilities at the RWTP must be probed to its
limits. The "efficiency" of a system which first centralizes
all sludge for treatment, then pumps it to a remote site, then
seeks to spread the sludge throughout the southern Willamette
Valley, and then remotely landfills sludge not so applied must
be questioned. There is great danger that MWMC's rush to secure
state and federal funding will result not in the required "timely,
orderly and efficient" public facility, but, rather, in a
"Conastoga Wagon" for sludge management in the Eugene/Springfield
area.
C. The Establishment of a Sewage Management Facility
at the "Coburg Hills Site" Would Violate the State
Land Use Goal of Energy Conservation
The establishment of any sewage facility at the "Coburg
Hills Site" would also violate state Land Use Goal #13: "To
conserve energy." This goal further states that:
Land and uses developed on land shall be managed and
controlled so as to maximize the conservation of all
forms of energy, based upon sound economic principals.
The DEIS recognizes that establishment of a remote sewage
management facility at the "Coburg Hills Site" would be most
energy consumptive (at page 170):
If the Coburg Hills site were used, electrical energy
consumption would likely increase somewhat because
sludge would have to be pumped a greater distance
from the RWTP. ... It is likely that the overall
haul distance [to reuse sites] would be greater
from Coburg Hills because it is not centrally located
to the grass seed growing areas of the upper Willamette
Valley.
Thus, in the case of the "Coburg Hills Site," as the force
main would need to be at least 2 miles longer than that required
to either "Site C" or the "Prairie Road Site," operating energy
consumption would greatest. Because of the additional pipeline
that would need to be built to the "Coburg Hills Site," energy .
consumption during construction would also be greatest. While
such energy consumptiveneas might be justified to bring the
sludge closer to the agricultural application areas, this is
DEIS Comments Page 10
A-78
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not the case with the "Coburg Hills Site." This site is most
remote from not only the RWTP, but also from the potential
agricultural sludge reuse areas. To build such excess energy
consumptiveness into the MWMC sludge management system would
be a violation of State Land Use Goal #13.
D. The Establishment of a Sewage Treatment Facility
at the "Coburg Hills Site" Would Violate the State
"Urbanization" Land Use Goal
The establishment of any sewage treatment facility at the
"Coburg Hills Site" would also violate state Land Use Goal
#14, which provides in part: "Urban .growth boundaries shall
be established to identify and separate urbanizable land from
rural land." "Rural lands" are defined to be "those which
are outside the urban growth boundary and are: (a) Non-urban
agricultural, forest or open space lands or, (b) Other lands
suitable for sparce settlement, small farms or acreage homesites
with no or hardly any public services, and which are not suitable,
necessary or intended for urban use." A map outlining the
Eugene/Springfield Metropolitant Urban Growth Boundary is
attached hereto as Exhibit "F". In commenting on this urban
growth boundary, the 1982 Metro Area General Plan, at page
1I-E-14, states: "The separation between urban and urbanizable
lands and rural lands formed by the urban growth boundary creates
a sharp distinction between ultimate urban uses and agricultural
uses on rural lands."
The location of any sewage management facility at the "Coburg
Hills Site" would breach this required "sharp distinction"
by imposing upon an area that is unquestionably rural an urban
facility so massive in scale that it is larger than the neigh-
boring City of Coburg itself. The imposition of such a clearly
urban use far beyond the metropolitan urban growth boundary
would, thus, violate state Land Use Goal #14. This is especially
true as the Coburg rural area here potentially burdened by
this facility will not be directly benefitted by it. Neither
the City of Coburg nor the Coburg Hills area is planned for
inclusion in the MWMC wastewater management system. This is
in contrast to the River Road/Santa Clara area, which lies
within the planned service area for the MWMC sewage management
system. (1980 MWMC Sludge Management Program, pages 3-1;
3-10.
DEIS Comments Page 11
A-79
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V. THE DEIS INADEQUATELY EVALUATES AND UNDERSTATES THE ENVIRONMENTAL
AND ECONOMIC IMPACTS UPON THE CITY OF COBURG AND COBURG HILLS AREA
The DEIS inadequately evaluates and understates the environ-
mental and economic impacts of the proposed remote sewage
laggon/drying bed facility upon the City of Coburg and the
Coburg Hills area. The impacts most inadequately addressed
in the DEIS are the potential for surface water and ground
water contamination at and around the "Coburg Hills Site" and
the visual/economic impact that development of the massive
sewage management facility would have on the Coburg area economy.
A. The DEIS Inadequately Evaluates and Understates Potential
Surface and Ground Water Contamination At and Around
the "Coburg Hills Site"
The DEIS fails to adequately evaluate and understates the
potential for surface water and ground water contamination
at and around the "Coburg Hills Site." A significant reason
for this is EPA's failure to perform any analysis whatsoever
of the specific soils underlaying this proposed site. As stated
on page 7 of the DEIS, "subsurface conditions at Coburg Hills
relatively unknown." The DEIS, at page 86, more bluntly states
with regard to the "Coburg Hills Site," "subsurface soil condi-
tions have not been explored." This is of especially great
concern because, had EPA contacted the owner of proposed "Coburg
Hills Site," he could have informed the agency that substantial
amounts of gravel exist at this site. This significantly
increases the risk of contamination of surrounding water supplies.
The importance of such missing information is magnified
by the DEIS1 recognition, at page 81, that groundwater flow
at the "Coburg Hills Site" trends toward the City of Coburg.
As discussed in the joint resolution of the City of Coburg
and Coburg Planning Commission, attached hereto as Exhibit
"C", the City has recently had substantial problems with contam-
ination of its water supply. This fact and the possible incre-
mental impact of locating the remote sludge management facility
at the "Coburg Hills Site" is not even discussed in the DEIS.
Additional problems with the DEIS1 consideration of ground-
water contamination include EPA's reliance on well monitoring.
Well monitoring is not documented in the DEIS to be capable
of eliminating, much less reversing, groundwater contamination.
The DEIS also fails to discuss any contingency plans should
ground water contamination at the "Coburg Hills Site," or any
DEIS Comments Page 12
A-80
-------
other site, be greater than anticipated. This is especially
significant in the case of the "Coburg Hills Site" as cuts
of up to 7 feet will be required to provide level areas for
drying beds, thus "increasing the possibility of encountering
adverse soil conditions, such as a permeable sand and gravel
aquifer at shallow depths." (DEIS, page 86).
The potential contamination of surface water sources by
the establishment of a sewage management facility at the "Coburg
Hills Site" is also significantly understated. The first
potential source of such contamination is from the proposed
seven mile long force main route. As the DEIS recognizes:
The force main route to the Coburg Hills Site
crosses the Willamette Main Stem, the McKenzie
River, and the upper portion of Muddy Creek.
Due to the McKenzie's high water quality and
use, any large spill that entered the river
would significantly alter water quality.
The DEIS further recognizes that "[r]upture or leakage of
the sludge supply or supernatant return pipes could result
in a significant impact on surface water quality," at page
110, and that the force mains would be above ground at river
crossings, at page 134.
Despite this recognition of the potential for contamination
of the Willamette Main Stem, McKenzie River and Muddy Creek,
from either a low-level undetected leak or a major break in
the pipeline to the proposed "Coburg Hills Site," the DEIS
fails to adequately assess the potential environmental and
economic costs of such direct contamination. For instance,
the DEIS fails to specify what the economic and environmental
costs would be of a major rupture proximate to the McKenzie
River. Nor does the DEIS recognize the possibility that such
a rupture could be caused by a vandal's single sludge-hammer
blow. By running the force main, exposed, directly over the
Willamette and McKenzie Rivers and Muddy Creek, EPA would be
exposing not only those in the immediate vicinity of the "Coburg
Hills Site" to contamination, but also untold numbers of people
and wildlife downstream to great risk. Such potential impacts
must be fully analyzed in an environmental impact statement.
Additionally, although recognizing that the highest
risk to surface water quality exists at the "Coburg Hills Site"
due to the presence of the Muddy Creek Floodplain, the DEIS
fails to assess at a reasonable level of detail the likely
impacts of contamination of the Muddy Creeks Irrigation Project.
Muddy Creeks Irrigation Project has an extensive irrigation
network that irrigates approximately 6,000 acres. The Project
DEIS Comments Page 13
A-81
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originates at Armitage Bridge on the McKenzie River and finally
empties into the Willamette River at Corvallis. One of the
laterals to this Project is Daniels Creek, which runs immediately
adjacent to the proposed "Coburg Hills Site." The 102 members
of the Project grow a diverse variety of crops, many for human
consumption. Despite this, the health and economic impacts
of any significant contamination of the Muddy Creeks Irrigation
Project have not been addressed in the DEIS.
B. The DEIS Inadequately Evaluates and Understates the
Visual and Economic Impacts of any Sewage Facility
at the "Coburg Hills Site"
The DEIS also inadequately evaluates and understates the
visual and economic impacts of any sewage facility at the "Coburg
Hills Site" upon nearby landowners, businesses in the
Interstate 5/Van Duyn Road Interchange area, and the City of
Coburg itself.
The high visibility of the proposed "Coburg Hills Site"
from homes along Van Duyn Road is shown by the photographs
attached hereto as Exhibit "G". In failing to specify the
number of homes so impacted, the DEIS fails to recognize recent
county zoning approval for a cluster subdivision along Van
Duyn Road to include an additional 30 homesites. All of these
residences will be south of the proposed Coburg Hills facility
and, thus, directly subject to the odors emitted from the sewage
lagoon/drying bed complex.
The DEIS also fails to even consider the potential economic
impact of the proposed facility on businesses in the Interstate
5/Van Duyn Road Interchange area and on the City of Coburg
itself. As the DEIS states at page 171, "[t]he Coburg Hills
site is easily visible from Interstate 5." Somehow, despite
this clear recognition, the DEIS absolutely ignores the economic
impacts of this fact. Drivers heading south on Interstate 5
pass the proposed site, including 35 to 50 acres of sewage
lagoons and air drying beds, approximately one-half mile before
the Van Duyn Road/Coburg exit. It is certain that viewing,
and quite possibly smelling, such a massive sewage facility
will directly affect the decisions of a significant percentage
of south-bound drivers as to whether or not to take this highway
exit. The resulting impact on interchange and downtown Coburg
businesses is obvious, yet the DEIS does not even mention,
much less discuss and analyze, this direct economic impact.
This is a major failing of the DEIS. This potential for placing
a huge economic burden on the Coburg area by the locating of
a massive sewage lagoon/drying bed facility immediately adjacent
DEIS Comments Page 14
A-82
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to Interstate 5 cannot be ignored by EPA.
Similarly, the City of Coburg itself would be directly
impacted by the establishment of the proposed facility at the
"Coburg Hills Site." There would not only be a lessening of
interchange traffic through the city, and consequently a reduc-
tion in downtown business, but also a change in the overall
livability arid attractiveness of Coburg. This impact, though
perhaps not readily quantifiable, is nonetheless real. Large
truck traffic through downtown Coburg during both construction
of the sewage facility and as part of the planned agricultural
reuse program would also undoubtedly result from establishment
of the proposed Coburg Hills sewage facility. The DEIS cannot
simply ignore or superficially mention these impacts. EPA has
an obligation to thoroughly analyze the social, economic and
environmental impacts of all alternatives under its consid-
eration.
VI. SUMMARY AND CONCLUSION
The DEIS fails to consider a reasonable range of both system
alternatives and alternative sites for the proposed remote
sewage lagoon/drying bed facility. EPA's selection of the
preferred alternative system is also flawed because of its
undocumented assumtion that there will be a continuous market
for agricultural reuse of sludge. The locating of the proposed
remote facility at the "Coburg Hills Site" is inconsistent
with state and local land use law and, for this reason, would
be illegal. The DEIS fails to adequately address potential
surface water and ground water contamination and the costs
of such occurences. Finally, the DEIS grossly understates
the visual and economic impacts of locating the proposed
facility at the "Coburg Hills Site."
Once an initial agency decision has been made, such as
that to implement MWMC's and EPA's preferred alternative system,
there is a tendancy for all subsequent investigation and analysis
to tend justify that decision. The danger in this is that
all possibilities are not then vigorously explored. The parties
to these Comments urge EPA to thoroughly investigate all avail-
able technologies for the MWMC sludge management system, partic-
ularly those technologies that can manage Eugene and Springfield's
sludge "on site," without unnecessarily intruding upon lands
and people not benefitted by the proposed system. It is only
after such a comprehensive inquiry has identified the best
practicable technology for managing Eugene and Springfield's
waste that any site for any remote MWMC facility should even
be considered.
DEIS Comments Page 15
A-83
-------
Should that consideration become necessary, the remote
site should be located on non-exclusive farm use land, unless
impossible, within the urban growth and system boundaries.
It would only be appropriate to consider a site such as the
"Coburg Hills Site" for a MWMC facility after such a comprehen-
sive analysis and this consideration would legally need to
include the consideration of numerous other potential remote
sites. The DEIS, thus, prematurely and inadequately considers
the "Coburg Hills Site" for the potential location of the pro-
posed sludge lagoon/drying bed facility. Locating such a
facility at this site will be firmly and continuously opposed
unless and until all other reasonable possibilities are exhausted,
as is required by the law.
Respectfully Submitted,
Jim Melamed
Attorney at Law
259 E. Fifth Avenue
Eugene, Oregon 97401
(503) 345-1456
DEIS Comments Page 16
A-84
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A RESOLUTION opposing the location of a sewage -facility on the "Ceburg
Hills Site" as proposed by the United States Environmental Protection
Agency and the Metropolitan Wastewater Management Commission.
V '
WHEREAS the City o-f Coburg Planning Commission and City Council finds
that: •'..-..'
1. A-fter public notice and hearing o-f the citizens of the City of
Coburg, there is substantial and concerned opposition to the location
o-f a sewage facility on the "Coburg Hills Site" and NO support
•therefor was received.
*
2. The City of Coburg may be adversely affected both physically and
economically by the potential location of & sewage sludge storage
facility near the City
-------
•facility should not be within Coburg's area of influence, but rather
within the Wastewater Service District.
Specifically, the proposal:
a) has not addressed Coburg's planning process in terms of
coordinating the MUJMC's objectives and programs with those-of our
local jurisdiction;
b) recommends the growth of urban services from the Eugene/Springfield
area into Coburg's area of influence without any benefit to Coburg's
urban service programs and plans;
c) thus suggests essentially unplanned urban growth within the Coburg
area without adequately addressing the issue of local livability;
d) has inadequately addressed potential adverse affects to the
preservation of scenic and natural resources as well as Coburg's
ongoing program of highlighting historic heritage goals; and
e) has given inadequate consideration to the compliance of this
proposed land use with Oregon's statewide goals and guidelines.
5. Loss of commercial appeal: Certain existing businesses and
potential future businesses which contribute tax revenues to the City
of Coburg rely heavily upon freeway traffic for trade. Anything that
might jeopardize this trade and subsequent present and future revenue
to the City and School District is of concern to the Planning
Commission and City Council. The acknowledged visual impact (per the
EIS) from the freeway, as well as the unknown but potentially serious
odors caused by the sewrage operation, might have an adverse influence
on the attractiveness of those businesses serving the travelling
public. This could have an adverse affect on both the businesses-
individually and the City. •
Specifically, the proposal has inadequately addressed:
a) the probable adverse economic affects on Coburg businesses
depending on the traveling public and hence on job opportunities
within the Coburg area;
b> the reletec! adverse affects on City revenues; and
c) potential adverse affects on local property values.
6. The plan has further made inadequate assessment of potential
problems associated with:
a> increased mosquito and rodent populations; and
b) increased truck traffic in an already conjested Coburg area both
during construction of the facility and in sludge removal/dispersal.
7. There has been insufficient consideration given to alternative
sites end se-Jeoe disposal methods.
J.'Ol-v THEREFORE the City cf Coburg Planning Corrrrsi ss i on and City Counc i !
RES.OL'-'E AS FC'LLO-'S:
"C" - 2
A-86
-------
1. The proposed location of a sewage sludge storage facility on the
"Coburg Hills Site" by the United States Environmental Protection
Agency and the Metropolitan Wastwater Management Commission is hereby
strongly opposed.
2. The City of Coburg shall lend its name and support to comments
being drafted by attorney Jim Me lamed, in addition to those made
above, in opposition to the establishment of any sewage facility at
the "Coburg Hills Site", as described in the Draft Environmental
Impact Statement to the Metropolitan Uastewater Management Commission
Sewage PI an.
This resolution was read once in full and once by title at the
December 1, 1983 joint meeting of the Coburg City Council and Planning
Commission whereupon it was put to a final vote. -
r
The vote of the City Council was:
Yes: 6
No: 0
Abstention: 0
The vote of the Planning Commission was:
Ye=: 6 ''-...
No: 0 •
Abstenti on: 0
SIGNED AND APPROVED this 2^ day of December, 1983.
C.W. Brought'on, Mayor
Tom R. Boi-.'erman, Planning Commission Chair-man
ATTEST:
Connor, City Feeorder
"C" - 3
A-8 7
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December 12, 1983
COUNTRYVIEW INVESTMENTS '••:+
3324 Regent
Eugene, Oregon 97401
Mr. Richard R. Thiel, P.E.
Environmental Evaluation
U.S. Environmental Protection
Agency
1200 6th Avenue
Seattle, WA 96101
Dear Mr. Thiel:
For the past year most of our effort has been towards
gaining approval for developing 250 acres for cluster
housing in the Coburg Hills area. During all of the
numerous discussions and meetings there has been no
comment made with reguard to the. sludge location on
property adjacent to that under consideration for
development. In October we finally received notice of
the proposed site. By this time approval and the
plat had been completed.
We hereby register our objection to the Coburg Hills
site for the sludge since it is directly adjacent and
upwind to the approved 30 cluster home sites. These
sites are ready for construction.
The Lane County Commissioner, Bill Rogers reported in
the first week in December that he had no knowledge of
the development site for the sludge in our area.
Any communication should be directed to us at the above
address and return communication will be handled through
our attorney Thomas Hoyt and the attorney representing
our zoning, Al Johnson.
Sincerely ,
Bob Meltebeke
President-Owner
A-88
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December 14, 1983
Mrs. Young, EPA
I am much concerned about the planned placement of
Eugene's sewage sludge on Site "C" or Prairie Road sites
because of the danger of groundwater pollution from that
sewage into our well water supply and that for Junction
City wells. I strongly urge you not to place that
toxic sewage on our water supply!
Ve have found no place where EPA or NWMC have any
protection provided for the people of this area for
either their water supply or their land being permanently
destroyed by the toxic effects of the sewage.
Sincerely,
DEC U l..j
S
•>• .
A-89
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lane County Local Government Boundary Commissioni new city. November 4,1983
Ms. Nona Young -EPA Region X, ret Eugene-Springfield-MWMC "Site C" Phase II EIS.
U.S. EPA -.Local* efforts to have this area in Oregon become more than three tines the
h*x*rJ>:-c.m national average from waterborne diseases, which Oregon is now said to be
by Associate Health Professor William Andermsn, Oregon State University.
U.S. G A 0 - The wasting of federal funds in consolidating two old treatment plants
shortcomings to.beowimg concentrated in only one outfall of sewage wastes
into the Willamette River, north of Eugene and outside its its UGB on land
and into the only potable groundwater source for many rural households,and
for Junction City.
U.S. Department of Justice - The methods being employed to have trespasses be made against
STATE OF OREGON STATEWIDE COALS and the local METROPOLITAN
FLAN adopted by Eugene-Springfield-Lane County, both of
which include protecting the environment in those goals •
and plans.* »«
-------
November *, 1963
LCLGBC, H Y, U.S. SPA, U.S. GAO, U.S. Dept. at Justice, page 2i continuing 2, B , l),a),
However, staff qualifies both tha 150 gped and the less than 100 gpcd as being
"average".. This says that peak dry weather flows could be 300 gped or the later
200 gpcd, respectively. Bfcge B-I-2 of staff's report says the Maxima dry weather
day is 68 agd, and this 66 agd.divided by 293,700 population in year 2000 is
231 gpcd for design year of the new plant. This is very conservative when HH-SC
is figured for 266 gpcd and CH2M Hill figured. 265 gpcd. This essentially 25 gpcd
would alter the design year peak flow against the new plant by 9.38 mgd.
b) Or, this 25 gpcd could be the additional infiltrations from leaking sewer lines.
3. The RR-SC Urban Facilities Flan Citisen Advisory Teaa (CAT) Meeting ainutes of
September 27, 1983 have that The new plant is being built because the existing plants
cannot aeet the increased hydraulic deaand caused by infiltration (This is substantiated
by the Eugene old-plant builder having been reported as saying that the plant should
have aore capacity at the time the old plant's problems started - several years ago.).*;
and "House connections between the house and the right-of-way have 60-90$ of the leaks."
A. Including the 1975 *tudy inforaation that Eugene had infiltration and inflow (I/I)
of 1,000+ gpcd(and Springfield had 850+ gpcd of I/I'),and this say not have been
known to~"the builder-engineer of the old Eugene plant, could account for the old
plant not having treating capacity during winter rain and rainstorms. These are
the tiaes when the old Eugene plant was and does becoae overload, and during the
. cannery waste load in the late summer and fall.
B. The present Eugene population of over 100,000, aultiplied by its I/I of 1,000+ gpcd,
would have the old plant's capacity-being washed-out with 100,000,000 gd, which is
additional to the. old plant's normal treating needs. Ne wonder the raw sewage is
so extensively bypassed to the Willaaette River from Eugene's three bypass puap
stations to the river.
C. "The river elevation is the single sost important thing affecting our storm and
sanitary sewers..." is credited to Mr. Allen, who was associated with the old
Eugene plant. During moderately high river level, even several feet below flood
stage, the river backs up into the outfall pipeline frem th»;plant.
l) CH2M Hill oust have known this to have had a primary effluent pump station in
the new plant plans, and the new plant's outfall pipeline has the same installed
bottoa-of-outfall-pipeline elevation as the old plant's outfall line. The MHMC
has ignored this singularly important fact because that primary effluent pump
was removed from the plant plans.
a) This is varified in the June 11, 1983 MWMC minutes, page 5» "Mr. Pye explained
that CH2N Hill has submitted a proposal for design of increased capacity for
the West Irwin Pump Station (built and in use since 1965) and force main.
This system was impacted by raising the headworks of the (new) treatment
facility when the primary effluent pump station was eliminated because of
value engineering cost saving design recommendations." CH2M Hill would appear
' to have not been proposing the design "recommendations" for the elimination
of the primary effluent pump station which.was included in its plans.
b) Eliminating this primary effluent pump station from.the plant plans has been/
is the largest influence in the new plant being not able to force effluent
from the plant to the river when the river level restricts or stops the
effluent from going to the river. This is a major "error".
c) CH2M Kin's 1975 study gives Springfield's I/I, adjusted to 1980 - as is
Eugene's I/I, at 850+ gpcd. Springfield has the population of approximately
-------
November **, 1983
LCLCBC, N T, U.S. EPA, U.S. CAO, U.S. D«pt. of Juatico, page 3« continuing 3.D.l)t
Eugene's tost site K DC test site shows hlgeat sulfate La December, as does its
K VIII2 test site, but its K VIII test site shows highest oulfate in Kay. These
are wet season months.
2) RH-SC test sits J IX shows highest sulfate in March. It is down-gradient from K X.
RR-SC test site J VI shows highest sulfate in December, down-gradient from K VII.
RR-SC test site H VII shows high sulfate in Kay and July, down-gradient fro* K X
and J IX.
RR-SC test site G VIII shows high sulfate in January and July, down-gradient from
K X, J IX and Eugene's trunk sewer line to the sewerage plant.
RR-SC test site G VI shows high sulfate 'in April and July, down-gradient from
the above listed test sites.
RR-SC test site G V shows high aulfate in March and declining in May toward the
sulfate reading of February, down-gradient from the foregoingly listed test sites.
RR-SC test site F VII2 shows high sulfate in April and July, down-gradient from
the foregoinuy listed test sites in the north-northwest aquifer flow.
RR-SC test site F VIIuhcsa. hi^h sulfate in January and July.
RR-SC test site EVIIlfchows high sulfate in June, down-gradient from the sewer plant.
RR-SC test site E VII shows high sulfate in July, * * * » * * .
RR-SC test site E VI shows high sulfate in October and August,.down-gradient in
the main aquifer flow channel.
RR-SC test site D VIII shows high sulfate in June, down-gradient from the old plant.
RR-SC test site D VH shows high sulfate in November and May.
RR-SC test site D VIoshows high sulfate in April and Kay.
RR-SC test site D VIg shows high sulfate in January and Hay.
RR-SC test site D VI shows high sulfate in Kay.
RR-SC test site D IV shows high sulfate in November and June.
RR-SC test site C VIII shows high sulfate in November and July.
RR-SC test site C VII shows high sulfate in November and July.
RR-SC test site C Vl£ shows high sulfate in January and March.
RR-SC test site C VI shows high sulfate in October, November and July.
RR-SC test site C V shows high sulfate in October and Kay.
RR-SC test site C IV shows high sulfate in November and July.
RR-SC test site C IV£ shows high sulfate in January and Hay - a surface site.
RR-SC test sits C III2 shows high sulfate in March - a surface site.
RR-SC test site C II shows high sulfate in November.
RR-SC test site C I shows high sulfate in November. The location is Just east of
the airport.
RR-SC test site B VII2 and B VH show high sulfate in January and May.
RR-SC test site B VI and B VI show high sulfate in October, May and July.
RR-SC test site B V shows high sulfate in February.
RR-SC test site B IV shows high sulfate in October, November and June.
RR-SC test site B I shows high sulfate in November and Kay.
RR-SC test site A IV shows high sulfate for every month tested, except August. It
is close to a cow barn.
RR-SC test site A III shows high sulfate in November.
RR-SC test site A l£ shows high sulfate in November and May.
3) The above listed surges or crests of sulfate flow through and via the aquifer
channels flows do indicate two and some areas three surges or crests during the
one year test, with monthly readings/testings. - when they VERB tested. The crests
do indicate two to three sources of sulfate. The B IV test site is in the aquifer
channel which has the highest changes in water level between the wet and dry
seasons. It is also in the north-northwest flow pattern of the aquifer. This does
indicate the sulfate is from RR-SC AND EUGENE'S leaking sewer lines.
-------
November 4, 1983
LCLGBC, N Y, U.S. EPA. U.S. CAO, U.S. Dept. of Justice, page 4, continuing 4. A
Obviously, the installed septic tanks are the more environmentally acceptable
alternative to the conventional and leaking of raw sewage sewer systems, which
Eugene's system definitely does do, as does Springfield's sewer system.
5. The Eugene-Springfield-MWMC has provided a new plant with doubtful treating abilities
and aore doubtful peak hydraulic flow capacity.
A. RR-SC is "planned" to be sewered with a peak hydraulic flow of 12 ngd. RR-SC now
has approximately 25,000 residents; it is "planned" to have 80 percent increase in
sewered population by year 2000. Its year 2000 is then approximately ^5,000, as
part of the total metropolitan area sewered population of new growth of 1^7,500.
RR-SC is then 1 (one) part of its ratio to'the total "planned" growth of 3.16 times
the total RR-SC year 2000 population. RR-SC peak hydraulic flow of 12 mgd, when
multiplied by 3.16, should provide the peak hydraulic load increase against the
new plant at of 37.92 ngd.
l) However, the new plant's peak hydraulic flow capacity is said by a Eugene
Public Works employee, the same one who is on record pertaining to the extensive
infiltration of house to right-of-way sewer pipelines and who appears to be
substantially correct in that the plant is being built for the purpose to allow
for such extensive infiltrations, to be 153 ogd. And, the new plant is to need
191 ngd peak hydraulic capacity by year 2000. 191 mgd minus 153 »gd is 38 mgd.
a) The new plant being short 38 mgd for a peak hydraulic load increase of 37.92
mgd says that the growth since the plant was engineered at 153 mgd to-date
should be into overload against the new plant, even before it goes on-line.
b) The increasing infiltrations fron the further deteriorating now installed
swer lines fron the house to street right-of-way should also further overload
the plant's peak hydraulic capacity.
c) The INSTANT peak flows from rainstorms should also further overload this new
plant's peak hydraulic capacity. This may have been the considered factor
which has prompted the installation of a diffuser at the Willakenzie pump
station, at the end of the East Bank Interceptor which transports -or it is
supposed to transport all of Springfield's sewage to this pump station. The
diffuser spreads the raw sewage bypasses for dilution in the river, just as
the plant's outfall line diffuser will do.
The cost of this bypass diffuser and the fact in its being placed at all does
create the impression in which bypassing of raw or primary trated sewage is
anticipated to be much more regularly utilized than MWMC's spokespersons are
admitting. This indicates no-growth in all areas now sewered.
6. The October 1983 EPA Region X EIS,pertaining to the MWHC's Phase II sludge handling,
discusses four options. The option/alternative 3 has the least environmental impacts.
This alternative 3 is the same Phase I sludge handling which has been forced upon the
MWMC with the delay caused by the need for the ELS.
A. The persons involved in promoting this EIS appear to have protection of their
environment in mind and actions, while the HVMC did not have environmental protection
in mind when considering that MWMC is already on record as believing the Phase II
Site C is OK with which to proceed. Site C is the more environmentally susceptable
of the four alternatives. Hopefully, EPA Region X will make its dissatisfaction
with such an erroneous conclusion become known to HVMC in the immediate future.
l) The Phase I sludge handling equipment is understood to be moved to the Site C
location, if MWMC is allowed to misuse that site. The misuse of Site C seems to
include extra costs of land and utilities service which are now available on the
plant-site. These extra expenses are considered to be the costs required by
MWMC to have MWMC be in position to further assault our environment. If DEQ and
EPA allow and fund this further fiasco against our environment, both should be
rendered asunder or would deleting both agencies be sufficient? Not sufficient!
2) This EIS also has that continuing Phase I through the design; year =2000 would
cause "..., the RWPT (new plant) wastewater treatment, sludge thickening, and
digestion capacity would also have to be expanded." This is translated to mean
that the new plant is net now even built to do the job of treating and peak
hydraulic flow capacity,being dispensed to the public as being now in place.
This translates to Site C and/or any other site being environmentally assaulted,
other than on-site. Soil and water conservation has not yet included that farm
land would be taken out of production and off the county tax rolls.
a) Any off-site move would cause the county residents, who are not receiving
"benefits" from MWMC's fiasco, to be in the position of involuntarily
supporting the Eugene-Springfield-MWMC sewering complex/ tKe F«'vrco.
b) MAC minutes for March 1981 contain the statement that the dewatering at the
plant would have been necessary to decide before June 1978. Now, here is the
Phase I intended to do the dewatering at the new plant-site. Some THINGS do
NOT compare well. This is the condition which seems to dominate this plant
project.
c) This condition also appears to be operant to the Terry Street force main
extension to the new plant. This force main is not needed; the existing-
since-1965 Vest Irwin pump station and force main, while the pump is straight-
line more than 50 percent worn out, is pumping more than 16 mgd. a
~
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November b, 1983
LCICBC, N Y, U.S. EPA, U.S. CAO. U.S. DEFT, of JUSTICE, page 5. continuing 6. 2 . c)»
This existing force main is capable in transporting approximately .33 agd.
All which is needed is to nave the new puapa and the rebuilt pumps have...
the saae scalier solids-clearance than the old pump(s) had and protect
them with a screen snail enough in aesh to prevent oversize solids froa
getting into the pumps(s). This would offset the error in the higher
headworks.. Logical, reasoning provides the conclusion that CH2M Hill
had this type of solution for avoiding the costs for the Terry Street
force rain. After all, the total aaount of sevage to be transported to
the plant is 25 mgd, not 33 *-«d» from the west Eugene sewer project.
d) This EIS has on page 8 that Site C would take 125 acres of agricultural
land from use. The Register-Guard's October 28, 1983 page 15C article has
that "...The commission (KWMC) adoped a resolution designating an additional
125 acres south and west of 'Site C' as a potential location for the sludge
disposal facility." This "additional" land uore than doubles the lo.-.s from
agriculture which the EIS considers necessary, ar.d this r.ora southern l~nd
is closer to the families who have been ItMers in opposing M'.-.'HC's locating
any facility for sewage over their only water supply source.
e) No logical reason exists to have permanent (ll more years) facilities be
built on-site, when "temporary (5 years)"facilities on-site has been so
environmentally the least objectionable. Use the old plant remaining components
for storage over the winteri those remaining components could have been used
for the seasonal wastes processing and avoided the potential misuse of Site
A-l for industrial toxics. The cannery waste single-line, not the required
dual-line which was NOT installed, has large cylindrical components along
that line which look as though they could be used as Junction boxes for
later connections from the industries which are in the area west of the line
now, and more could be connected further north.
f) Using the old plant would have saved all of the funds wasted on Site A-l,
which was not cost-effective, compared to overland flow, when it was built.
CH2M Hill was supposed to be the primary engineering firm for the sewer plant project.
It has in the 208 Plan that land application of sewage sludge is too expensive and
should not be considered further. Its admonition has not been utilized; this helps to
explain how the old Eugene sewer plant's problems have been so exorbitantly costly to
have continued in this new plant. Economic growth would have depended upon reliable
sewer service all year around, and not having this is saying that no economic growth
can occur and abide by state and federal requirements, when they are enforced. '•.
Sewering HR-SC to this total mesa would assure no economic growth in this whole
metropolitan area. If RR-SC is not required to sewer to this new plant, its becoming a
new city will give it the necessary chance to investigate and select alternatives which
could lead to one area, at least, being able to attract economic growth. The Judco dryer
is able to dry sewage and septage sludge. Connecting it to the O'Connor solid waste
burner and converting the solid wastes and sewage/septage sludge to heat exchange gain,
with steam turning turbines to power electric generators and the hot water condensate
heating homes and greenhouses, would provide the cost-efficiencies necessary to attract
more economic growth.
As was said by Mr. Jake Jacobaon at the meeting last night, the new city of Santa
Clara could not do worse than Eugene is doing. Perhaps better understanding of his
references would be of value toward making correct allowance to have the incorporation
process proceed.
1. Eugene charges three separate times on land square footage charges for storm and sewer
system. Three times on development charges, which are for square footage of the total
floor area and the square footage of the eapermeable-to-downward-penetration-of-water
surf acesi normally, the thought would occur that the floor area of the improvement
charge would be sufficient, but the roof over the improvement-also may be considered
as being an impermeable surface, as would be the parking lot, sidewalks, etc. The
funny-damn in all of these charges is that they are listed in Eugene Code as user
charges, while the usual county property taxes are considered as "user" charges, which
are also still charged against the land and improvement(s).
2. Where, -outside Russia and such "backward countries",would the chairman of a boundary
commission be challenge^for ex parte contact with neighbors,who did not even know
that he is a commisioner, on a subject of such import to all persons in the area being
considered to fora the new city of Santa Clara, where this commissioner lives?
A. This was travestied by a boundary commission staff member, who is hired on contract
for commission work from the Lane Council of Governments, which includes Eugene
and Springfield. This appears to have the Eugene and Springfield members of the
boundary commission to also be challenged.
l) All of those members and staff, who live in Eugene or Springfield,also stand to
become relieved of part of the new sewerage plant's costs, if the incorporation
petition is denied, thus leaving the area subject to being annexed to Eugene
and have to pay approximately $1,500 per householdjfox the plant costs, plus a
sewer system cost of $3,900 to $10,000 for a sewer system,to save them $200.
John C. Neely. Jr. - 1600 Horn Lane - 97*K*
A-94
-------
for December 6, 1983
SPA meeting in the Springfield City Hall,
Re: Metropolitan Wastewater Management Commission's (MWMC's) Phase II Sludge
Management Plan's Environmental Impact Statement (EIS).
Page 5 of this EIS on Phase II of MWKC's Sludge Management Plan has, "EPA could
offer funds for ... some combination of processing and reuse/disposal methods not
considered in a single alternative described in the EIS or Sludge Management Program.
Although this is unlikely, it could be done for environmental or econmic reasons."
If this is not double-speak, EPA is saying the likelihood of such alternative(s)
would be substantially increased when environmental AND economic reasons are
correlated.
This correlation exists via combining the O'Connor solid waste burner with the
Judco Dryer. O'Connor's solid waste burner is structured to utilize the heat from
burning solid wastes to heat water to steam, which is then available to turn a
generator for production of electricity or perform other work from heat exchange for
economic gain. The ash from the burning should also provide for recovery of the heavy
metals which are in the sewage sludge. This would avoid their hazarding the land and.
aquifer potable water supplies under that land.
This process is most economic for local bonds payers and federal taxpayers. It
will also serve to protect the environment. Mr. Jud Buttner and Mr. O'Connor are
teaming their expertise and inventions for the purposes in attaining the environmental
AND economic recovery of resources. These two engineers are directly and indirectly
assembling the solution to many of EPA's present and future impasses in environmental
protection with providing this process for utility economically. All which is needed
is to have the EPA burn its biases, which produces open-mindedness, before starting
to study this correlated mechanical combination.
Mr. Buttner has said that EPA is relaxing its public domain requirement. This is
a late correction, but it is better than no correction. EPA Region X should also
make every effort to obtain their new, correlated brochure when it becomes available,
which is expected to be soon. Study it, see the record of low particulates, non—wear
and reliable performace characteristics, then invest a few thousands of dollars to
save many millions of dollars and save our environment for US.
This mechanical combination, which was portable as just the Judco Dryer and could
be portable in a smaller combination, could be put to work at any solid waste dump
site, such as Short Mountain, for its initial testing and performance verification.
While it is there, process the whole mountain of landfilled solid wastes.
All thinking persons are able to associate the fact that this process will
displace need for the very expensive sand filtration, which was removed from this
activated sludge process plant's plans because it does not retain heavy metals and
toxic chemicals. These can now be recovered from the ash residue, those which have
not recombined to non-harmful substances via pyrolysis and incineration.
Incineration is an end-product of pyrolysis: chemical decomposition or other
chemical change brought about by the action of heat regardless of the temperature
involved. Pyrolysis and incineration are both listed in this EIS's page 3-5's chart
for Base Sludge Utilization/Disposal Options as being acceptable as base alternative
components.
These two engineering specialists are innovative, so the funding for this machine
they are combining for utilization of wastes should be at the extra 10 percent for
innovative and alternative technology. It is an excellent solution to present and
anticipated trespasses against our economy and our environment.
Kr. Buttner and Mr. O'Connor are congratulated for their expertise and their
cooperation producing the solution for protecting our environment and our economics.
Naturally, their solution eradicates need for any further grants for application
to land and, because the soils in this area are not sufficiently acid to hold the
pathogens nor sufficiently alkaline to hold the heavy metals or toxic chemicals from
sewage sludge in the soil mantle, penetrating laterally and vertically to polluting
the potable aquifers. This means that Site C, Prairie Road site, Coburg site are not
necessary to become contaminated.
£\~~ .7 J
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for EPA's meeting, MWMC EIS. 12/6/83. page 2
This perspective definitely does recommend continuing Alternative 3 until the
Judco Dryer and O'Connor solid waste burner is installed and becomes operational
AT THE PLANT SITE to then obviate need of any further grants from EPA, from the
federal taxpayers money. Eugene's and Springfield's MWMC has sufficient bond funds
remaining to install this unit, rather than dissipate more funds to further attack
the land, the aquifers and the peoples' environment.
EPA could withdraw its funding of the Terry Street force main project beyond its
extension to and connect into the pressure side of the existing West Irwin force
main as a funding source for installing the Judco Dryer and O'Connor solid waste
burner on the new plant site. Page A-3 has in paragraph three that, "NPDES permits
for wastewater treatment plants include sludge disposal conditions where possible,..."
This is possible, and Alternative 3 should be continued until this becomes reality.
Funding the Terry Street force main beyond tying into the existing West Irwin
force main appears to be extraneous because the repair of the West Irwin pumps, which
are straight-line now worn more than 50 percent, and the new pumps could also be with
the next size smaller solids-clearance with smaller mesh grids ahead of them to stop
solids larger than will clear the solids-clearance, are pumping more than 16 mgd in
this condition. One hundred-percent-function pumps of the smaller solids-clearance
would be expected to move more than 33 rogd through the existing force main even with
the fifteen-foot more pressure head from the elevated plant headworks. Only 25 mgd
is planned to be needing transport to the year 2000, leaving approximately 7»5 to 8
mgd reserve capacity even under the most optimistic anticipated growth.
The comparison for the existing West Irwin force main's 30-inch diameter being able
to transport 25 to 33 mgd is in the East Bank Interceptor's 103 mgd engineered to go
through the Willakenzie pump station 5t*~inch force main to the new plant and its 15-
foot higher headworks. The blue MWMC pamphlet just received in the mail says that,
"The objective of the improvements (West Irwin Pump Station) is to increase pumping
capacity." MWMC-Eugene appear to be using the more expensive means to do the job.
The pumping capacity increase will be accomplished with reducing the rebuilt and
new pumps to the smaller solids clearance than was used for the transport of sewage
to the old Eugene plant. The West Irwin force main's 30-inch diameter pipeline has
the cross-sectional area/25 mgd of 28.*f to the EBI's Willakenzie force main's 5^f-inch
diameter pipeline cross-sectional area/103 mgd of 22.2, which indicates that the West
Irwin force main, now in use,will transport 25 mgd with less friction-loss than would
be active when the Willakenzie force-main-to-the-new-plant is transporting 103 ragd.
Keep in mind that the 5^-inch diameter Willakenzie force-main has an additional 14-
to-l6 years more engineering experience-level for design capacity than had the West
Irwin force-main.
This engineering experience-level-more also indicates the new plant's original
plans were more accurate for the job than would the plant be after it had several of
its components removed. This EIS's page 139, paragraph 3 has that Facultative Sludge
Lagoons (FSLs) function as secondary digesters. The two secondary clarifiers, which
were removed from the plant's original plans, could have been utilized as secondary
digesters on-site, rather than having to have the extra costs and environmental
hazards involved in having to go off-site to construct FSLs/ secondary digesters.
Obviously, the EPA has accomplished a commendable job with its EIS showing that '
Alternative 3 has the least environmental impacts and it must be utilized to fulfill
the requirements for which the local and federal funds were intended to accomplish -
protect the environment. However, at the 7 to 8 AM MWMC Advisory Committee (MAC)
meeting, just yesterday, the majority of members present did vote to recommend that
Site C be recommended to EPA. Those persons voting for this have transgressed!
1. The EIS page 132's "All reasonable attempts should be made to avoid any additional
nitrate and bacterial contamination of the groundwater and to control existing
sources of contamination if groundwater is going to be a continuing source of
drinking water for residents in this area." The groundwater definitely is to be
the ONLY continuing source of drinking water for residents in this area and in any
other off-site area.
2. The EIS page 133's "The drying process tends to concentrate nonvolatile substances
in a given volume of sludge, including heavy metals and some toxic organics."
A-96
-------
for EPA's meeting, MWMC EIS, 12/6/83, page 3
When considering the bar graph Industrial Flow (MGD) CONCENTRATION INCREASE to
PRESENT FLOW of the eleven listed toxics on this page, which accompanied the MAC
minutes for April 15, 1981, and to the estimated domestic flow dilution, this off-
site drying process would compound those toxic pollutants concentration by the same
ratio as that of the removal of moisture, which then pricipitates environmental
hazard increase against that sole source drinking water supply. And:
"More serious health threats to these water supply wells would come from flooded
septic systems and leaky sewers that contain raw sewage." Septic tank systems do
NOT emit raw sewage because they are air and water tight. The septic system's
effluent is treated anaerobically and, according to the July 1982 North Carolina
Septage Study, there is considerable doubt that septic systems emit sufficient
organisms to cause disease conditions. This is in sharp contrast to this study's
conclusion as it pertains to the activated sludge process, which is that activated
sludge process does create endemic to epidemic disease conditions when this sludge
is land applied.
This EPA EIS does substantiate this study's conclusion. Yet, the MWMC majority
of MAC-person representatives present at yesterday morning's meeting have indicated
extensive disregard for their down-gradient neighbors' continuing good health. This
also applies to Eugene not repairing its leaking sewer lines, of which the house to
street right-of-way sewer pipelines infiltrate "60 to 90# of the leaks" and which
are considered to be not cost-effective to repair. They are in the highest pipelines
of the gravity flow sewer systems, so they only infiltrate during the rainy and high
groundwater seasons. They exfiltrate raw sewage during the dry and low groundwater
seasons. Therefore, these exfiltrating sewer lines non-repair are causing "More
serious health threats to these water supply wells..." This ongoing and can-only-
worsen situation is to be compounded with land application of sludge from an activated
sludge process plant.
To what extent are the majority persons in the agencies and other promoting of
environmental hazards placements organizations liable as accessor!es-after-the-fact
when violence by the persons being hazarded results in injury or death to any of
those hazards placements promoting persons? In the past, many deaths have occurred
over disputes which pertain to water. When a sole-source potable water supply is to
be threatened, whose life or health is hazarded becomes a factor to be considered in
all decisions adversely affecting that water supply. The federal funds are meant to
reduce this additional hazard, not increase it.
EPA's funding only the Alternative 3, until the Judco Dryer and the O'Connor solid
waste burner combination is installed and operational, will certainly reduce the
potentials in adverse reaction potentials which could accompany funding any of the
off-site locations being considered in this EIS.
Those of us who are active in this process of selection, and who live in this
River Road area where the new plant is located, did not want to have this new plant
be located in our residential area. However, now that the new plant IS in our area,
the general consensus is to have the "... wastewater treatment plants include sludge
disposal conditions where possible,..." This is possible; it is even probable. The
complimentary result will be the numerous residents surrounding this plant-site area
will be the ones who are in the most advantageous position to assure that the plant's
performance potentials are fulfilled,and that its pollutants are not hazarding our f
down-gradient neighbors' sole supply of potable water.
Even Eugene's residents, since the plant site has been recently annexed, will also
help assure the environmental factors are fulfilled. This is the primary function for
which local and federal funding were intended by U.S. Public Laws 92-500 and 95-217.
The-chicken-will have-come-home-to-roost when the EPA only funds the Alternative 3
and the Judco Dryer and O'Connor combination, all AT THE PLANT SITE.
EPA may contact MR. Jud Buttner at (503) 7*4-7-3315. His mailing address is 40303
Deerhorn Road, Springfield, Oregon 97^77 for his soon-to-be-delivered new brochure
pertaining to details on these two engineers combined efforts to help solve the
ongoing and worsening pollution problems which hazard more and more now healthy
people.
A-97
John C. Neely, Jr.
- l600 Horn ^ne ~ 2ugene, OR
-------
Ms. Ernesta Barnes, December 7. 1983
Administrator,
Ms. Norma Young,
BIS Coordinator,
Mr. Thiel,
Hearings Chair, Draft SIS on MUMC's Sludge Management, last night.
1200 Sixth Avenue
Seattle, Washington 93101
Res M/S 443
Last night's hearing's Bart One went as-usual, its Part Two's public testimony
is ALL in opposition to off -site sewage sludge handling - placing - treatmenti the
only ones favoring flinging-»the~"M8tuffw-over-the-»fence were the 6a«* Tgje/^aj^pear
to be trying to convert a "bed pan" to a "potty-with-bail-for-flinging1*. Part Three,
quest!on-suggestion-answar period, developed more questions than for which answers,
satisfactory ones, were provided. Some answers provided were not satisfacory nor
accurate.
One question asked was related to the rate of groundwater flow in the Site C-
Prairie Road Site. The answer given by Brown and Caldwell's representative was
200 feet per year. This answer by him appears to be based in some relationship to
nitrates-plume flow in the general River Road/Santa Clara area from Sweet's reports.
Using or misusing the 1978-1979 RR/SC Groundwater Study's nitrates-plume flow is one
more of the major errors being employed to arrive at very faulty conclusions. This
study's Raw Data sheets,':the information in them being the basis upon which Sweet's
reports should have been based - as well as that of B ft C's representative, provide
extensive contrast information.
Sweet's RR/SC Groundwater Final Evaluation's Plate B map of test sites locations,
having the scale of 1,000 feet equal 7/32s of one-inch, were transferred to a map
of the general area which has the scale of one mile equals 1 5/8s inches. The Raw
Data shows aulfate as one of the other-than-nitrate components of the groundwater
for which quality numbers are provided. Sulfate is integral in the groundwater with
nitrate. However, sulfate speed of migration with the groundwater flow definitely
does disclose a much faster groundwater rate of flow than does nitrate-rate-of-flow.
From Eugene-area K, X test-well-to*RRt»-* IX test well is 3A-inch, which is 6/8ths-
inch or 6 x 5,280-ft/13(8ths-inch), or 6 x 406.1-feet, or 2,436.6-feet. Sulfate did
travel this distance, from its high reading in August £a- dry month) from K X to J IX's
high sulfate reading in April (a wet month; in approximately 6 months, or sulfate did
travel in the groundwater for a distance of approximately 4,873 feet in one year.
However, only one sulfate reading is listed in the Raw Data for the whole year of
testing (only two readings for nitrate for J IX are listed for the whole year of
testing - for excuses said on its test sheet, which are extraneous to this point),
so iroa EugeneBs K X test well to Eugene's K VUI2 test well is 5/8ths-inch on this
same general area map. Sulfate moved from August at K X to December at K VIII2 high
reading a distance of 2,030.5 feet in four months, or approximately 6,061 feet in
one year, or more than one mile.
Obviously, the groundwater flow is much more than 200 feet in one year. This does
cause the question of why does nitrate-plume only move 200 feet in one year?*and why
is there a nitrate-nplume" at all? This DEIS says in several references that nitrate
moves freely with the groundwater flow. However, the nitrates in this groundwater
test do not move-freely-with-the-groundwater-flow, or so the Sweet Reports indicate.
The accurate answer for both questions reason to be based in the fact that the July
1982 North Carolina Septage Study, which is conspicuous by ITS ABSENCE from the list
of references stated for this DEIS, says that heavy metals are not retained in the
soil, mantle when the soil mantle's pH is 6.5 or less, which says that heavy metals
are held in the soil mantle when pH is greater than 6.5. And other studies show that
sands hold heavy metals and toxic organics.
This DEIS shows that the groundwater is more alkaline than 6.5 pH, and core samples
show gravel and sand to be in the groundwater aquifer channels. This DEIS also shows
that heavy metals and toxic organics remain with the nitrates in the sewage sludge.
So, the grondwater aquifer channels' sand and higher-than-6.5-pH are retarding nitrate
movement to 200 feet per year, which forms the ^plume" and says that heavy metals are
A- 98 in tn* groundwater, which question is theni what is the source of the heavy metals?
-------
Ms. Young. EPA'a DEIS, MWMC, 12/7/83,
Page 2
The answer is, again/ obvious. The fact in the choice in the Raw Data being the
nitrate precipitate method with cadmium, and the cadmium precipitate method then
producing higher nitrate readings of 5.5 percent to 100 percent more than has been
produced with the alternate and comparable method for establishing nitrate in water,
definitely proclaims and establishes that cadmium was in the groundwater AT THE TIME
OF TESTING. When both test methods were used on the same well or test site on the
same date, the obvious answer is that both tests were made from the same sample of
water from that test well or site.
Domestic sewage does not contain measurable amounts of cadmium. Industrial wastes
do have measurable quantities of cadmium. Cadmium is in the urban industrial sewage
wastes in Eugene, together with ten other known toxics of concern. This says that all
eleven of these tested-for-in-the-sewage-from-Eugene are in this domestic on-site
system groundwater, because these toxics are from the sewer lines exfiltration places
in the dry and low groundwater level as are the infiltration places in the sewer lines
during the rainy and high groundwater seasons. The fact in the September 27, 1983
River Road/Santa Clara Urban Facilities Plant Citizen Advisory Team (CAT) minutes
saying that the new plant is being built because the two old sewerage plants do not
have peak hydraulic flow capacity for all of the infiltration and inflow,*and that
60--£-90# of the I/I is from the toilets, and the* other normal inlets of waste to the
sewer system - such as industrial toxics and heavy metals, to the street right-of-
way do establish that domestic sewage - raw - and toxic industrial wastes migrate
into the RR/SC groundwater. The sands in the aquifer channels and the groundwater
pH being more than 6.5 then hold the heavy-metals-laden nitrates and have formed the
so-called "nitrates-plume" in this RR/SC area's groundwater, together with the lesser
amount of nitrates normal to domestic sewage effluent from on-site systems.
Prothero's 1975 Thesis says that on-site anaerobic systems produce less nitrates
than do the aerobic systems, such as are the trickling filter and activated sludge
systems of central sewage and industrial wastes processing plants. This_DEIS also
says that anaerobic digestion of sewage produces less nitrates than anaerobic sewer
plant processes. This DEIS also says that nitrates are added as odor control, which
would then produce more nitrates in the groundwater under the land upon, which such
sludges are land applied, together with the heavy metals and organic toxics in that
urban, industrialized sewage sludge. Nitrates are supposed to be the concern of EPA.
Mr. Lowekron made the remark that,when pH is less than 6.5 in the soil, less of
the sludge is applied. This does not agree with the North Carolina Septage Study. It
does indicate that NO heavy metals-content sludge shoud be applied to land with less
than 6.5 pH. Again, the North Carolina Septage Study is conspicuous by its ABSENCE
from this DEIS's references. Prominent in this DEIS's references are statements made
by the persons who have caused the affected and concerned citizens to have caused
this DEIS to be performed.
Would Mr. Lowenkron, if asked, have said that less sludge would be applied to land
which has a pH of more than 5*0 when the sludge contains pathogens, etc.? Probably.
If so, this would appear to be another "error", particularly when considering the
presentation made by Springfield City Councelor Fred Simmons. His admonition to
reevaluate methods now employed has more recent knowledge than appears to have been
employed by this state's authorities to have Oregon be at three times the national
average hazard from waterborne diseases. This DEIS also refer* . to no harm coming
to healthy persons. This DEIS says that harm can come to those persons who are not
healthy. How would they have become unhealthy? Via the groundwater becoming so
polluted as the result from inefficiencies and/or indifferences of authorities?
"Government is a trust, and the officers of government are trustees; both the
trust and the trustees are created for the benefit of the people - Henry Clay.1*
Please notice that Henry Clay does not say for officers of government to tryst to
the detriment of the people.
Dry sewage sludge to 50 percent solids in the Judco Dryer and then burn it, with
other solid wastes,in the O'Connor solid waste burner to produce heat exchange gain
"... for the benefit of the people.", their health, their environment.
The B & C representative responded to Mr. Elliott's favoring this burning of wastes
with the remark that it is not cost-effective. He also said that heat exchange gain
of up-to four times the heat required to dry the sewage sludge and other solid wastes
prior to burning it to produce energy would defy the first law of thermodynamics.
-------
Ms. Young, EPA'o DEIS, MWMC. 12/7/83,
fage 3
Is Mr. Kreugel (?), the B & C representative, a bit confused? Is the first law of
thermodynamics that energy is not destroyed, that it is Just transformed? If this
is not so, then many scholars have studied the wrong references. He, as an employee
of a company which is employed by officers of government, is acting in the stead of
officers of government or in conjunction with officers of government. This does say
that he is supposed to be bound by the trust assigned to officers of government and
that all decisions are to be "... for the benmfit of the people." His perspectives
appear to be very similar to those of Mr* fye. This DEIS has been promoted by the
people, so they appear to be objecting to the perspectives of Mr* fye and to the
similar perspectives of all other employees of officers of government*
Neither of these two employed-by-officers-of-govenment persons taure been read to
have utilized a more realistic rate of RR/SC-Site C or Prairie Road Site or even at
the Site A-l groundwater flow with comparing the groundwater flow zaite indicated in
the newspaper articles pertaining to the spilling of toxic formaldehyde in the
Russian River, northern California, on March 26, 1982. On March 2?, 1982, "Officials
urged people not to use water from wells within 100 feet of the Russian River until
they are tested for formaldehyde,..." On March 28, 1982 the AF article has, "About
1.000 residents in Guemeville were asked to close private wells within 400 yards of
the river..." This change in groundwater rate of flow expectation was increased by
1,200 percent, for a difference of 1,100 feet more in tone-day-. 1,200 x 365 - 538,000
feet in one year, or more than 100 miles in one year. Viruses and bacteria are also
reported to have fast movement in groundwater.
At the meeting last night, Mr. Richard Thiel commented that pollutants could be
removed from slow-moving groundwater by pumping it out, cleaning it up and return it
to the aquifer, but this could not be done with fast-moving groundwater. Therefore,
the actual, rather than assumed, rate of groundwater flow must be established before
any resulting decision could be valid for pumping-to-clean an aquifer. This aquifer
being pumped out would be a waste of money and create a false sense of security when
the causal factors of exfiltrating sewer lines have not been terminated. They are to
not be repaired because their repair is said to be not cost-effective.
The exfiltrating of raw sewage and toxics of several known named kinds, plus the
probability of those unnamed, because MWMC requested that only the eleven listed
toxics be tested for, being hazards to the groundwater during the dry and low ground-
water seasons, would continue to degrade the aquifer as a drinking water source. This
is very similar to applying activated sludge process sludge to land in this general
area, which has the pH ranging from 5.0 to 6.5. It acts as a "funnel" for all of the
pollutants to go through the soil mantle and into the aquifer. This amounts to there
being a major "leak" in a sewer line to the groundwater, or many such "leaks".
This DEIS also calls the sludge from this activated sludge process "digested",
while it also addresses odors from the product of this process. Saying it is "digested"
is not a fact- when odors are associated with it, because it is not even near the humic
status of a digested-anything. Activated sludge is the just prior step to fulvic acids
in the "Ultimate analyses of organic materials in the fossilization pathway-(in dry,
ash-free weight percentages).", while humic acids are midway between activated sludge
and the ultimate increase in carbon content of 96 percent in anthracite coals.
"Fulvic and humic acids consist mainly of complex hydrophilic polyelectrolytic
polymers of benzene rings that are variously substituted, partially to completely
(which can be equivalent to saying fulvic as partially and humic as completely), with
either or both phenolic and carboxyl groups, together with large amounts of aliphatic
earboxylic acids; up to about 70 percent of humic and .fulvic acids may be made up of
these subunits (which could explain their similarities but not their odors differences),
which form water-soluble and water-insoluble complexes with metal ions and hydrous
oxides and interact with clay minerals and hydrophobia organic compounds such as
alkanes. About 10*8 stable free radicals are found per gram of humic or fulvic acids.
Fragmentation patterns derived through mass spectrometry reveal remarkable similar-
ities between soil humic acids, model humic acids, composted straw, peat, and
melanins (humic substances secreted by fungi). Many of the chemical and spectroscopic
properties of model humic acids are also indistinguishable from those of soil humic
acids and melanins the reaction period required for the production of humus in
nature is unknown. Humic acids differ from fulvic acids in having larger molecular
weights and from humins(the alkali-insoluble component of humus) in having smaller
molecular weights. A-100
-------
Ms. Young, EPA'3 DEIS, MHMC, 12/7/81,
"Fulvic acids undergo a considerable amount of demethanation(posaibly preferential
losses of methylene) in Doing derived from foodstuffs. Moreover, in the event that
they are precursors of humlc acids, they lose an appreciable amount of car boxy 1 ea
routei this is in line with the analytical data. Pulvic and hundc polymers are linked
with aadno acids, carbohydrBtes, peptides, and amino sugars, probably through bonding
of nitrogen to carbon on a phenol or by quinimine formation, as well as possibly
through peptide linkages, and by way of the thioether linkage .of sulfur to ring
carbon."(rei Sludge Decomposition and Stabilization - Roy Hartenstein, SCIENCE, May
15, 1981, Volume 212, Number 4496, pp. 7*0-748)
And, "In view of this and because humified material appears to be nonamenable to
putrescence, it appears proper to say that sludge is stabilized when it becomes
humified." This is far down the carbon cycle from "digested" sludge, so the use of
the terb "digested", that of reduction for ready use or application, or to subject to
or transform by digestion, is most misleading when not sufficient negative ions have
been returned or transferred to the results of such "digestion" to prevent reverting
to putrescence. This "digested" sludge has not progressed from the stage of putrescence
and the misuse of polymerization as a "packaging" of putrescence at the plant is then
transferred to land application, and misuse the land as part of treatment plant and
expose the people to this harming of their potable water aquifer; this is all most
foreign to-benefit-of-the-people.
The thioether linkage of sulfur to ring carbon would be expected to occur in the
groundwater's reduced oxygen ion transport after exfiltrating raw sewage has reduced
the negative ion concentration of the rain and river recharge from nearly one hundred
percent dissolved oxygen ion transport. This should explain why the groundwater tests
showed sulfate movement to be much faster with the groundwater flow than nitrates flow,
particularly when considering the nitrates to be "tethered" to the sand via the heavy
metals.
That "Pulvic acids undergo a considerable amount of demethanation in being derived
from foodstuffs." is evidence that the B 4 C representative appears to have ignored as
a. source of additional heat exchange gain when burning the "digested" sludge. This is
also a form of testimonial as to the only-partial-digestion derived from activated
sludge process. Additionally, as the plant's capacity becomes further overloaded, the
only-partial-digestion is further reduced, which leaves more methane in the sludge,,as
being more indicative toward putrescence occurring upon land application. If this type
sludge is dried and then burned, the heat exchange gain would be increased via the
presence of the additional methane-producing potential. The dryer could be "hooded" to
capture this methane for work conversion, if it is shown to vent during the drying
process. This would also contain reasons for processing the cannery wastes at/in the
old Eugene sewerage plant.) the residual sludge, only-partially-digested, should be .
an increased source of heat exchange gain and reduction of costs from operation of the
old plant for the few months during which the cannery produces fractions from food-
stuffs.
The "engineers" on this new-plant .project and components appear to not have had
the benefit of chemists nor physicists in this plot, plan or project. Opportunities
for heat exchange gain should have been explored and be incorporated with components
which do provide heat exchange gain,such as the Judco Dryer and the O'Connor solid
waste burner. When opportunities for protecting the environment and make the whole
processing of sewage less exorbitantly expensive to the users-public and the federal
government are ignored, the officers of government are not performing the trust to
the benefit of the people.
The domestic sewage is derived from foodstuffs and it is planned to be approximately
one hudred percent more by the year 2000, so heat exchange gain would be incremental.
A hand written note is included with the Raw Data of the 1978-1979 RR/SC Groundwater
Study. Above the listing of eleven toxics and their characteristics is a blocked-in
"Notei Total present industrial flow - 2.6 mgd. Year 2000 projected industrial flow
- 5»1 ngd. Projected industrial flow increase - 2.5 mgd."f which compares satisfactorily
with domestic flow increase for dilution. It would, however, provide for doubling the
mass of toxics going through the plant, to the land, and into the aquifer - a sole
potable water source. Dry the sludge, burn it, obtain heat exchange gain, and help to
protect our environment. Protecting our environment is supposed to be THE requirement.
A-101
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Ms. Young, SPA's DEIS, MWMC, 12/7/83,
Page 5
This hand written note is titled "Effluent limits comparison7; Its [Toxic, Arsenic
(As), is listed as Present Qp (mgd) being 0.14- and Present Qp, + 2.5 mgd, as being
2.64; this shows an increase in As of 2.6^/0.14, or 1,885 percent. Its Toxic, Cadmium
(Cd), is listed as Present Qp (mgd) being 0.05 and Present Qp, + 2.5 ngd, as being
2.55; this shows an increase in Cd of 2.55/0.05, or 5*100 percent. Its Toxicsi £ead,
(Pb), Nickel (Ni), and Cyanide (Gn) are listed as Present Qp (mgd) being 0.13 for
each of then and Present Op,* 2.5 ngd, as being 2.63t this shows an increase in Pb,
Ni, and Cn of 2.63/0.13, or 2,020 percent. These are examples to compare to the bar
graph,of these same Toxics, which accompanied the MWMC Advisory Committee (MAC) minutes
of its April 15. 1981 meeting.
These minutes have on page 2 that, "..* Al Peroutka had written the report, and
that it had come from their research in trying to develop a logic for establishing
pretreatment standards or limits.
"Cook then directed the Committee to a chart which had been handed out (attached
and made a part of these minutes). He explained that this showed the method used to
take the arbitrariness out of the development of standards. He said that by selecting
a flow (those shown were based on the year 2000) one could pick off a concentration
that will utilize 100 percent of the allowable industrial mass. Cook added that it
was a good tool is to see where to establish a flow and see how it affects the con-
centrations.
"He further explained that the table assumes the growth from 1980 to 2000 will be
approximately 2,5 million gallons per day (mgd), and reiterated that half of that
growth will occur in each of the toxics. This amounts to 1.25 mgd in each of the toxics.
Rather than have industries adjust every year, Cook said the engineers thought it best
to plan for anticipated growth. Assuming all projections are maintained, the figures
should be valid until the rear 2000. Cook noted that the figures shown in the handout
material used current data.
"A concern was expressed about the engineers' ability to accurately forecast the
future in terms of industrial growth, and Cook said that responses received from
industrial representatives indicated that they would prefer a reasonable guess on
concentration and mass limits rather than new figures every year.
"Cook noted that the Eugene-Springfield metropolitan area is probably one of the
first to use a logical approach to create limits and standards. Most other cities •:..
use what other cities are doing. Ed Wilson added that a lot of cities adopt drinking
water quality standards or use 10 or 100 times that figure as their standards for .'-.,- '.
industry. He said he felt the MWMC engineers' approach was very well done, as there
was a 50 percent growth pattern built into the program.
"Jeff Siegel questioned whether concentrations would drop as the flow increases,
and Cook said that was correct because the mass is held constant. He said that Mass -
Concentration X Flow, so that anytime the flow is increased, to keep the mass constant.
the cudcentxution must be increased. •
"Cook explained that Peroutka's original concept for a pretreatment program had
proven infeasible as the it was too sensitive to flow; the engineers then tried a
'total flow* concept, on which their current recommendations are based. This concept
is based on actual industrial growth in the Eugene-Springfield metropolitan area.
"In response to a question from the audience, Cook explained that in reality the
flows with the concentration shown on the table will utilize 100 percent of the
allowable mass. He reiterated that most industries*will be able to meet these limits,
and that they are technologically achievable." (end of jits page 2)
This "table" or "chart" is titled "EFFLUENT TOXIC CONCENTRATION, A FUNCTION OF
INDUSTRIAL FLOW". Its line graph is for EFFLUENT CONCENTRATION (MG/L) of the eleven
Toxics out of 129 potential toxics of concern. Its bar graph, INDUSTRIAL FLOW (MGD)
has PRESENT FLOW marked in shaded units and its CONCENTRATION INCREASE is extending
those bars across the grid units without shading. "Present Flow"of Arsenic (As) is
one-half (l/2) grid unit} its "Concentration Increase" of As is twenty-five mora*c;~
grid graph units. This results in As increase of $0 times its present flow, or 5*000
percent, as compared to the hand written note's 1,885 percent.
Its "Present Flow" for Cadmium (Cd) is approximately three-fourths (3/*0 grid unit;
its "Concentration Increase" of Cd is approximately (*4'/») twenty-four-and-one-half more
grid graph units. This results in Cd increase of 32.66 times, or 3*266 percent, as
compared to the hand written note's 5.100 percent.
-------
Ms. Young, EPA'a DECS, MWMC, 12/7/83,
Page 6
Its "Present Flow" for Lead (Pb) is two and one-half grid units; its "Concentration
Increase" of Fb is twenty five (25) graph grid units. This results in Pb increase of
10.0 times, or 1,000 percent, as compared to the hand written note's 2,020 percent.
Its "Present Flow" for Nickel (Ni) is the same as for Pb and its "Concentration
Increase" for Ni is the same as for Pb. This results in Ni increase of 10.0 times, or
1,000 percent, as compared to the hand written note's 2,020 percent.
Its "Present Flow" for Cyanide (On) is one and one-quarter grid units{ its "Concen-
tration Increase" of Cn is twenty five and one-quarter more graph grid units. This
results in Cn increase of 20.2 times, or 2,020 percent, which is exactly the same as
comparing the hand written note's 2,020 percent.
These four examples demonstrate that considerable adaptations have been rendered
between the twot hand written reference and the graph grid bars. Neither of these
references agree with any intent to limit toxics concentration or mass of toxics. The
"engineers" are correct in that "... most industries will be able to meet these 'limits',
and that they are technologically achievable." Anyone should be able to technologically
be able to qualify as an "engineer" just with pouring more toxic pollutants into a sewer,
or into anything elset such as on land and into the aquifer, which is the sole source
potable water supply for many now-healthy people. However, they will not be healthy for
much longer.
Compare that Mr. Terry Smith, an employee of the Eugene Public Works Department, is
on meeting tape record of the CAT to have responded essentially that, if Cadmium was
in the groundwater to the extent indicated by the use of the Cadmium precipitation of
nitrates method produced 5»5 to 100 percent more nitrates than with the comparable other,
Bgl,method, deaths would occur. Consider the "100 percent" as that which would produce
deathi then Cadmium increase of 32.66 times, as is indicated in the bar graph, or 51
times, as is indicated in the hand written note, would produce death nearly instantly.
Keep in mind that the general consensus among scientists is increasingly tending toward
there not being a threshold at which Cadmium will not do harm to living cells and
organisms. The fact that animal and human life is comprised with-and composed of these
organic cells and other organisms should have caused decrease from PRESENT FLOW or
CONCENTRATION of TOXICS to protect these cells, organisms and human/animal life.
Such dramatic increases of toxics concentration, as is foregoingly indicated and
compared, should be able to be easily traced to their causal factors from the sewage
sludge applied to that land and into the aquifer, and into the living cells and organisms
of animal and human life and cause them to instantly, or nearly instantly, cease to
function. These results would cause such exorbitant cost increases against the then-
sewer-users as to have been much more cost effective to have dried and burned the sewage
sludge as the base component of the sewage treating process. DRY IT AND BURN ITI
And, "Cadmium is a toxic trace mineral that has many structural similarities to zinc.
There is no biological function for this element in humans....Dr. Henry A. Shroeder, a
trace mineral researcher, has developed a theory about cadmium being a major causative
factor in hypertension and related heart ailments... The liver and kidneys are storage
areas for ... cadmium..." (Nutrition Research, Inc.'s NliTKj.Tj.ON ALMANAC, pp. 62-63)
"The body's ability to use zinc is hindered by cadmium,...It is believed to contribute
to high blood pressure, cardiovascular disease, and kidney disease." (Robert D. Gutting,
Minerals, pg. 4)
So, many humans, who would be drinking such heavily increased pollution of their
water supply aquifer, are now predisposed to cessation of cells and organisms functions
from even slight increase in cadmium concentration. This exists when just considering
.this one toxic mineral. How much more devastating will this be when all of the adverse
reactions from the known toxics and heavy metals increases in this sludge are considered
together? Answer: much more devastating.
Consider that the dilution with domestic sewage flow was figured from ah experience-
level constant, or nearly constant, from Eugene's 240 gallons per capita per day (gpcd)
in 1980-1981. Its gpcd is now . said to be reduced to approximately 79 gpcd. This is
then concentrating the toxics by another six (6) times. This DEIS says that toxics do
increase more with the off-site drying-of-sewage-sludge process. MWMC is planning to
misuse any off-site location to cause such compounding of toxics hazard. EPA must NOT
allow this to occur. DRY IT AND BURN ITI ON THE PLANT SITE! This perspective should
cause EPA to demand refund of its grants funds and provide for finders-fee with such
recovery of those funds. They appear to be producing opposite to their origi1"31
A-103
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Ms. Norm Young, EPA1 a DEIS, 12/7/83,
Page 7
How the procession of events turned from benefitting the environment and economy
to harming both is explored chronologically. Page 2 of the April 15, 1981 MAC minutes,
quoted on page 5 of these comments, show that Mr* Peroutka had written the report and
that Mr. Cook is credited with having said that "...Peroutka's original concept for a
pretreatment program had proven infeasible as the-(sic) it was too sensitive to flow)
the engineers then tried a 'total flow* concept, on which their current recommendations
are based." This appears to clear Mr. Peroutka, except for possible participation in
developing this "total flow" concept presented by the engineers.
Page 5 of the MWMC Newsletter for April-May 1981 has, "Peat, Marwick, Mitchell & Co,
the Commission's (MWMC's) pretreatment consultant (the word 'engineers' is not used
here), has asked for input from MAC and the Technical Advisory Staff concerning methods
for developing prohibitive discharge standards for local industries. MAC held a special
meeting on March 18 to consider these questions and will continue the discussion at its
regular meeting April 1 and at another special meeting April 15"(l98l). The quoted page
2 is from that April 15 meeting of MAC. This April-May 1981 Newsletter continues with
"Representatives from industrial firms in the Eugene-Springfield area are welcome to
attend MAC meetings and contribute to the discussions."
Representatives from industrial firms in the Eugene-Springfield area participated
wih input, because this MAC meeting minutes page 2 has, ",...Cook said that responses
received from industrial representatives indicated that they would prefer a reasonable
guess on concentration and mass limits rather than new figures every year." How they
appear to have departed so radically from protecting the environment is also on this
quoted page 2 in "He (COOK) said that Mass - Concentration X Flow (this writer's back-
ground of reference indicates this chemistry-physics formula to be correct), so that
anytime the flow is increased, to keep the mass constant, the concentration must be
increased."
Mr. Cook's explanation of this formulas Mass - Concentration X Flow, "... so that
anytime the flow is increased, to keep the mass constant, the concentration must be
increased." is faulty. The correct explanation is "... so that anytime the flow is
increased, to keep the mass constant (should read 'to keep the concentration constant'),
the concentration must be increased (should read 'the mass must be increased')." So,
the correct use of the formula, Mass - Concentration X Flow, would reads to keep the
concentration constant, the mass must be increased anytime the flow is increased.
Amazingly and ALARMINGLY, Mr. Cook's explanation of this formula/equation appears
to have been misused to have the TOXICS CONCENTRATION be increased so radically and so
harmfully against people and their environment. This situation also brings forth the
subjects of experience-level, knowledge-background, intent and ethics of the participants
in such an astonishingly basic "error". However, even the misuse of this formula/equation
should not have produced 5,100 percent, 3,266 percent, nor even 2,020 percent increase
in TOXICS CONCENTRATION when the total increase in domestic flow dilution of the toxics
and the industrial flow of toxics are essentially equivalent at approximately one (one)
time, or 100 percent, increase from present (i960) flows to estimated year 2000 flows
of both domestic and industrial toxics/pollutants.
Again, amazingly and ALARMINGLY, "Cook noted that Eugene-Springfield metropolitan
area is probably one of the first to use a logical approach to create limits and
standards.'' What is logical in "... that anytime the flow is increased, to keep the
mass constant, the concentration must be increased."? Logic requires knowing that the
mass-constant requires DECREASING the concentration when flow is increased. People-of-
letters should have learned this fact long before they became people-of-letters, which
they may not be, or they may possess ulterior motives In having bypassed their probable
knowledge.
This consideration appears to be probable when including more of the MWMC Newsletter's
page 5> "Closer to home, controversy over the possibility of ground or (and) groundwater
contamination by land application of sewage sludge has emphasized the need to keep sludge
as free from toxic contamination as possible.
"The MWMC is developing a local industrial pretreatment program designed to protect
the biological systems of the new regional treatment plant and maintain a toxic-free
sludge through regulating industrial discharges to the public-owned sewer system." This
TOXICS-FREE SLUDGE maintenance program has been reversed to the TOXICS^COMPOUNDING
program. DRY THE SLUDGE, BURN THE SLUDGE, RECOVER THE TOXICS FROM THE SLUDGE. DO NOT
PUT IT ON LAND WHERE IT CAN SO SEVERELY ENDANGER LIFE CONTINUITY VIA THE GROUNDWATER.
A-104
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Ms. Young. SPA's DEIS, MUMC, 12/7/83,
Page 8
MHMC's Newsletter of August-September 1982 has on its page 5, "Industry accepts
pretreatment progxajti
"Two representatives of local industrial firms testified in support of MVHC's
industrial wastewater pretreatment program at a June 28 (1982) hearing, stating that
they felt it was fair'to industry. They were the only persons who testified at the
meeting although eight other representatives from industry were present. The entire
hearing was conducted within a 50-minute period, much to the surprise of MUMC staff
present." Why would the MWMC be surprised that industry accepted a free-ride? The rule-
of-thumb in establishing a functional balance is when both sides are still objecting to
some features in the proposal being considered for adoption. Industrie acceptance of
this "pretreatment" program does indicate the industry representatives received from
MWMC a "cake" with multiple layers of "frosting". Christmas came early for industry.
Also, this August-September 1982 MWMC Newsletter's page 5 is continued witht
"A member of the Commission's staff reported that in casual conversation following the
hearing an industrial representative explained that since industries had been involved
in the development of the program from the ba^innlnff,. they understood and accepted the
restrictions." What restrictions when MWMC'a "reasonable guess", preferred by industry,
has resulted in flow increase producing concentration increase to keep the mass of
TOXICS constant? The MASS of TOXICS will INCREASE when CCKCBHTHATICR is INCREASED,
whether the flow is increased or flow remains constant - the Mass - Concentration X Plow
formula or equation says this will occur. Compounding coaceatrmtimr of toxics, as has
been presented as planned to occur via examining the portents disclosed by the bar graph,
will compound the transport of TOXICS at any flow rate.
The inefficiencies or designs of the MWMC and its subcommittees majority members,, in
these particulars referring to industry,'s_ "pretreatment" of toxics, produces extensive
questioning of the efficiencies and designs of the results in all components of this
new activated sludge process plant since CH2M Hill reported that land application of
sewage sludge is too expensive and should not be pursued furtheri now exclusively pursued.
Mr. Richard Thiel reported that no compensation for damages to thexadversely affected
people would be forthcoming. He was asked about the "zero industrial pollutants discharge
to sewer lines by 1985". He responded that, although it is the result of legislation, it
is a GOAL that is not to be achieved by 1985* It will certainly not ever be achieved
when Mass - Concentration X Flow is so resoundingly mauled by promoters of industrial
development - and hang-the-consequences.
Page *t and 5 of this writer's input for the DEIS meeting on 12/6/83, not presented
at that time, is attached to this series of comments on this DEIS. The conclusions are
related to the perspectives presented on these eight pages.
John C. Neely, Jr. •An.C.tKtfo&i. - 1600 Horn lane, Eugene, OR
F.S.t this bar graph copy is the one earlier presented to Ms. Ernestm Barnes by Mrs.
Melva Barnes and Mrs. Eugene (Pat) Bohanan.
Il4 Jj^pLp. INDUS
. ! aurl r —?> • a'-f' T. I Lz
i ,.,^,-^M r/a».>TM
I i l i l ! i I ^Vj
-------
for EPA's meeting, NVMC SIS, 12/6/83, page *f
P St
Page 6 of this EIS, Impacts of Individual Alternatives, has that "EPA win not
be responsible for implementing all mitigations required. Local, regional, and
state agencies will be called upon to initiate those mitigations that are within
their functional capacities." Just reading this seems to allow this to be reasonable.
However, once comparative concentration is applied to this attitude, applying this
to so many inconsistencies discloses how so many illogical results have filtered-
through-the-cracks.
1. Page 7 shows Table S-l describing Alternative 2 (MWMC's Preferred Alternative),
while page 11 shows Table S-2 describing Alternative 1 (Centrifuges abandoned,
sludge stored in off-site FSLs(/secondary digesters) and air-dried, while Table
S-3 shows Alternative 3 and page 15 shows Table S-4 describing Alternative *f.
Considering general mental abilities to be as limited as they seem to be, the
conclusion is that Table S-l description could easily be confused with the
Alternative 1 and the Table S-2 description could easily be confused with the
Alternative 2, while no similar confusing factor is evident between Table S-3
description and Alternative 3» which also applies to Tabe S-4 and description -
for Alternative *K
The point being that this similarity was noticed in the new plant plans and their
alternatives descriptions! when the description for one alternative was under
consideration, it would be easy to associate this with the corresponding FLAN
number. This appears to have occurred, because the upgrading of the two old,
separate Eugene and Springfield trickling filter plants were said to be not-
appreciably-less-in-cost than to build the single, regional-concept plant. The
point being here is that this type of expression says that upgrading the two old
plants would have been at less-cost. This implies that cost-effectiveness has
been bypassed.
2. CH2M Hill's 1975 and 1977 studies provided definite information which was based
on its experience-level, while Brown and Caldwell's studies appeared to offset
much of CH2M hill's recommendations and directives. One of these, as ah example,
is that CH2M Hill said that land application of sewage sludge was toaexpensive
and it should not be .considered any further.
Obviously, this expensive information has been bypassed. This EIS being a treatise
on options for off-site land applications of sewage sludge are all which are
being considered. This is not consistent with protecting the environment.
3. Page B-5 shows Table B-3's chart with Utilization/disposal options. This is for
sewage sludge. The very similar conditions and mitigations are used on the Agripac
site. This indicates that the deposits on that land will have properties similar
to those in sewage sludge. And, the court decision pertaining to condemnation of
property for Site A-l did allow the condemnation for depositing sanitary sewage
on-the-site-being-condemned. Yet, DEQ's permit has only seasonal industrial/cannery
wastes to go on that property. Again, a part of law appears to have dropped-
through-a-crack because Oregon law only allows condemnation of property for three
specific reasons or purposes. The only one of these reasons pertaining to this
booboo, and a very expensive one, is that for sewage. So, no matter from which
perspective this particular subject is considered, the seasonal industrial Site
A-l should not have been allowed. It should not have had any financing from EPA.
EPA's foregoing quotation,saying it will not be responsible for implementing all
mitigations required, says that the local, regional, and state agencies are to be
held responsible for initiating those mitigations that are within their functional
capacities. DEQ is part of the state as an ag'ency. It should have stopped this
series of condemnations. It did not; it appears to, have violated state law in the
issuing a permit for any activity which required condemnation of agricultural use
property in private ownership for agricultural use in public or quasi-public
ownership. DEQ seems to be actively engaged in^byfassing its functional activities
responsibilities. The local and regional agencies personnel also have bypassed
their responsibilities when they need to have known, since they are also part of
the state's delegation of authoity, that these condemnations are outside state law .
for the purpose of using seasonal wastes for agricultural purposes. This is a
general failure of functional capacities of all personnel involved in this fiasco,
because local and federal funds are di'sipated on a project which has become not
legal. If no property owner had gone to condemnation, this would not have been known.
A-106
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for EPA* s meeting, MHHG £13,12/6/83, page 5
The fact in this being known as a natter of court record has the EPA participating
in violation of Oregon law. EPA's not being .. responsible for initiating this
•itigating measure says that federal funds have been expended upon an illegal plot,
plan, or project.
Bat (Mrs. Eugene) Bohanan has said that she spoke by telephone to Ms. Nona Young of
EPA*s Region X and that one of the particulars mentioned to Mrs. Bohanan is a rule
or process used by the EPA on projects which is called engineering value or value
engineering. Her understanding, and that of this writer, is that the word "value"
has the direct connotation in ONLY price of a project is considered at that tine.
If this is so, then environmental considerations in protection are NOT considered.
This could explain how the 10-inch dual force-main has been deleted from the "Agripac"
plot, plan, or project, which deleted the three specific reasons which Mr. Burd had
repeated as being required. The repeating of the requirements followed the first
statement by approximately one year. This figures as the environmental factors give
way to cost-effectiveness. Yet, this cannot be so, because the Site A-l is being built
when even the MWMC's literature said that Site A-l was nearly $2,000,000 more to build
and $35*000 per year more to operate and maintain than the overland flow option, which
is also said in MWMC literature to be more environmentally acceptable.
This necessarily says that EPA and DEft are involved with federal money waste, because
neither cost-effectiveness nor environmental protection have been properly considered
in this whole treatment plant and components series of projects, plans, or plots.
Not sufficient supervision by state or federal agencies, or because of them, the local
plotters or planners appear to have been - and still are - running-the-show-or-hide.
Since this whole sequence of events appears to have progressed to such a fiasco via
the local and generally unreliable authorities and-agencies - judging by the results
to-date, the EPA should now consider exercising its potentials in making corrections
by making sure that funding will only continue for the Alternative 3 &&<* the use of
the Judco Dryer and the O'Connor solid waste burner combination being installed ON
THE NEW PLANT SITE. This would achieve the environmental protection which can still
be attained. It should also be the cost-effectiveness solution, both with local and
federal funds.
This BUS says that the EPA has performed the function for which an EIS is intended
to demonstrate. It does demonstrate that the objections by the persons,r-who,are
involved in helping to cause this EIS to be performed, have been correct in their
analyses of the worsening aituation(s). This EIS also appears to remove EPA from any
seeming-complicity in the down-hill-slide, away from cost-effectiveness and the
environmental protection for which all of the involved funds were origionally expected
to accomplish. Non-funding the Terry Street force-main beyond the pressure side of
the West Irwin pump station and tied into the West Irwin existing force-main at that
point would be an excellent means for acquiring the federal funds for the Alternative
3 continuation, with and for adding the combination of the O'Connor solid waste
burner and the Judco Dryer* ON THE NEW PLANT SITE.
This arrangement would make the seasonal waste Site A-l obsolete, because the old
Eugene sewer plant could be used to process the cannery's wastes and the solids would
be on-site to be processed through the Jud Buttner's Judco Dryer and O'Connor solid
waste burner combination. The ash from this process in burning the seasonal wastes
should be acceptable for the Bag-market as fertilizer. And, as soon as the new law
becomes effective in 1985, to have ZERO INDUSTRIAL POLLUTANTS DISCHARGE TO THE SEWER,
the sewage-burning?-ash should also be acceptable for the Bag-market as fertilizer.
Other functions will be automatically corrected, if EPA does elect this route for
future protection of our invironment. Getting the MWMC in the fertilizer business
should be the most and last which should be expected from EPA. The most important item
which can possibly come from EPA electing this suggestion as THE solution is in that,
while the local authorities may deserve to have the pollutants come back to them in
the food they eat, from the land upon which they had intended to spoil and waste with
sewage pollutants, the public,which had no part in all of this having occurred to-date,
will not be made to suffer illness or death as the result from the biases of the local
agencies personnel, or their lack of expertise, or their complete lack of regard for
their and others environment betterment.
John C. Neely, Jr. & c.'-vx.
A-107
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Ks. Norma Young December 16, 1983
EIS Coordinator
EPA Region X
1200 Sixth Avenue Ret M/S W}
Seattle, Washington 98101
At the meeting last night, before a county hearings officer for the lane County
Commissioners, MWMC requested a Conditional Use Permit for what it calls "Alternative
1", which is the original Site C area and designated as Alternative 2 in the DEIS. Its
"Alternative 2" is the 125-acre site which adjoins Site C to the south of Site C, which
is one of the sites designated as Alternative 1 in the DEIS.
The "experts" told the hearings officer the same line of - ah, state-of-the-art as
was presented at the December 6, 1983 DEIS hearing. State-of-the-art, that which has
caused Oregon to be at three times the national average hazard from waterborne diseases,
is as an admission by those "experts" in not having included more recent references in
their considerations which demonstrate the shortcomings within state-of-the-art as it
is being practiced.
An objector to land application of the sewage sludge asked the rate of flow of the
groundwater. The response was, again, 200 feet per year. Mr. Edwards, of Sweet-Edwards
which made the reports on the 1978-1979 River Road/Santa Clara Groundwater Study, made
this statement. He also said that, in the Dispersion and Decay analyses at the Shirley
Street site, a down-gradient test well was pumped down to create a groundwater rate-of-
flow acceleration of approximately ten times the normal rate of groundwater flow. This
certainly does provide an admission in monkey-business with a supposedly scientific
experiment to establish, as a phase, a groundwater flow rate. This adapting of such a
test provides inexplicability in accounting for that study's specific reference to
the participants SURPRISE in the injected bacteria having migrated up-gradient to an
up-gradient test well. This may be indicative in the extensive deficiencies in the
presently practiced by them state-of-the-art, and against which people utilizing the
later references are so strenuously objecting.TV»*&*P»»»^-P»'*y«'»»tPct*<*»j»/.Ac»«y
Their SURPRISE at this phenomenon of up-gradient travel of injected bacteria should
have indicated to them that the direction and rate of groundwater flow is a combined
functional relationship of the groundwater level, at the time of the testing, and the
myriad interties in the sand-gravel channels of the aquifer, which were laid down so
many years ago, and in reference to which they will have to continue to be required to
just-guess, which is a sad reflection on their state-of-the-art and be an additional
indictment against their use of that older and extensively deficient state-of-the-art.
"Another local-resident objector said his experience-level has demonstrated that the
clay soils in the area, that which is depended upon for a lining for the FSLs, is not
impervious, but the clay soils are pervious to fluids. MWMC's literature and the DEIS
confirm this action, albeit indirectly, when they have expounded on the sludge being
a soil amendment which helps make the clay soils more and better workable in tilling.
Page 3t last paragraph of this writer's input on 12/7/83*quotes from the Sludge
Decomposition and Stabilization treatise by Roy Hartenstein, has that the fulvic and
humic acids "... form water-soluble and water-insoluble complexes with metal ions and
hydrous oxides and interact with clay minerals...", which is a substantiation in the
soil-amendment perspective and is an accent on the validity of that local-area person's
objections to the misuse of local clay soils as a liner for FSLs. The presence of the
fulvic acids,and humic acids 70 percent similarities to fulvic acids also being present
to act upon the pore perviousness of the local clay soils, which increases the speed of
the reaction of the acids in the pores of the clay soils to make the pores of the clay
soils larger and more rapidly to provide for the clay soils to become more pervious.
The "experts" appear to be providing in the sewage sludge the acids "moles" which
would be chemically "boring larger holes" very rapidly 'in an "impervious liner" which
is more pervious locally than the "experts" seem to include in their guesstimates.
This was one of the conditions inferred in this writer's input in reference to Phase I
at Short Mountain. Mr. Burd tried to reassure this writer in a, response letter. He has
totally failed in thr.t effort. His effort may be considered as effective as the
transcience of the dual-force-main requirement in the seasonal wastes transport pipeline
to Site A-l, which became transcient as the result of value engineering - which also
appsars to have excluded all of the requirements for environmental protection, that for
which the federal funding is intended to be expended; a major item which seems to have
been acted upon as local clays are acted upon by fulvic acids 30 percent unstable ions.
A-108
-------
Ms. Young, M/S Wj, 12/16/83, page 2
Further reference to unstable ionst At the Coburg City Hall meeting by the Coburg
residents, pertaining to this DEIS reintroducing the Coburg Hills site as an off-site
sludge disposal alternative, one of the audience asked an MWMC employee, Mr. Peroutka,
if air could be pumped to the plant site, a major source-area for acquiring the negative
ion more nearly saturated air being from above the nearby Willamette River. His response
was no. Does it reason to you, as it does to this writer, that pumping high negative
ionized air to the heavy fluids of sewage and aerating those fluids at the plant site
would have been more energy-efficient and environmentally protective than to instead
expend funds for an off-sit?location and expending expensive energy to pump the heavy
fluids to that off-site location for the same purpose in negative ion exchange from the
air to reduce the putrescence of* the "digested" sewage? The aeration energy cost is then
expended to facilitate the ion exchange and reduce the putrescence of excess unstable
ions to the stable ions characteristic in humified sewage sludge, and to reduce the
numbers of birds attracted by such putrescence, which is indicated by so many references
to odor in this DEIS.
Had the new plant been of the anaerobic design, the trapping and use of methane gas
could have been utilized .to drive negative ion generators which could have been located
in the air transport pipelines from above the nearby river to the plant - a very short
distance compared to the several miles of sludge transport pipelines to any off-site
location to obtain the necessary negative ions exchange from the air at the off-site
location(s). The negative ions are doing the job of reducing the amount of solids by
changing molecular structures of the components in the sludge/sewage. The high positive
ion excess from industrial pullutants, including solvents which also penetrate soils
pores, including clay soils, more rapidly than does the capillary action of pure water,
would reduce the amount of solids of sludge.
This DEIS, and repeated by the "experts" at last night's meeting, says that,when this
new plant goes on-line, the solids production will be manyfold more than the two old
plants produced. Logic requires considering that the two old plants had their separate
sources of negative ions for exchange, while their sewage will soon be combined at one
area and no increase in negative ions for the break-down of solids.; this fact must be
included in any remarks which are intended to explain how the new plant will produce
such an excess of solids. The connotation would include that polymerization has become
the substitution for negative ionization at the plant site. The polymers being the means
for "package" transport of solids molecules not broken down at the, plant site because the
limited air content of available negative ions has not been sufficient for the job of
work required to reduce the solids to their simpler molecular structures which would be
characteristic of humification.
The time required for nature to reduce putrescence to humus is said to be unknown,
in the treatise on Sludge Decomposition and Stabilization. However, the proposition is
becoming more often repeated that stabilization in warn climates would be approximately
one and one-half years for domestic sewage. This Eugene-Springfield area must be allowed
as being a colder climate, so the general reference is to double the time needed for
domestic sewage to become stabilized. The presence of industrial pollutants may then be
considered to be compounding the time for the domestic-industrial mix of sewage. This
would reason to be a compounding of time to reach stabilization to be a near/y dfr«xf
ratio to the amount of industrial pollutants in the domestic sludge dilution- of those
toxics.
An elderly lady, an owner of land in the area of Site C, presented the fact that she
and her husband own land which is assessed at $52,000 per acre. If all of the- land at
the area preferred by MWMC is similarly priced and would have to be paid, together with
the cost of the improvements on such land, the cost for the l?0-acr:e site would be in
excess of $8,8^0,000; the cost for the-125-acre site would be in excess of $6,500,000.
This recalls that CH2M Hill said that land application of sewage sludge is too expensive,
and it should not be further considered. CH2M Hill, as far back as 1975, reasons to be
absolutely correct in its ignored recommendation!.The Judco Dryer and O'Connor solid
waste burner combination su*ely would have ah installed and operational cost, even with
duplication for back-up units> be considerably less than for just land costs for
MWMC's biased from state-of-its-art preference.
John C. Neely, Jr.
1600 Horn lane u Eugene, Or 97^04
A-109
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HAROLD S.SCHRENK
FOrSJ.SCHRENK
91736 Green Hill Road
Junction City, Oregon 97448
December 6, 1983
u il"
DEC 9 W83
E. P. A.
Norma Young
12^0 6th Ave.
Seattle, Washington 98101 '*•••••
Re: E. I. S. Site C and Prairie Road Site
Dear Ms. Young:
Regretfully, we are unable to attend the meeting in Springfie'd, Ore as of this
date re the hearing for the location of sludge dumping ponds for the Eugene Municipal
system. However, we wish to use this means of registering with your agency our
very deep concerns and objections to the above named sites.
We have a small (5^ acres) farm just about three miles northwest of site C, and
the Pairie Road site. We have lived here for thirtyeight years and developed our
home and. business where we are trying to make our living in these trying times of
agriculture problems. These two sites will be placed over the direction of the
ground water flow through our farm, as well as those of all our neighbors. All
here in tnis area have shallow wells including the town of Junction City which is
in the pathway of the underground water flow on which site C and Prairie Road are
located. Our conerns are contamination of our wells and devaluation of our land
and homes due to the sludge dumping on these sites. Assurances by the management
of the 'A'aste Water Committee that all precautions will be taken to prevent such
contamination is not convincing the residents here this will not happen. The
engineers reports and findings say that contamination is possible to our ground
water from these sludge ponds. This would contaminate our living wells and drinking
water for people and animals alike. Due to the cost of replacing the well and
extensive water systems we now must have to operate our farm, replacement of such
an extensive system would be financially impossible. There may be economic recovery
for some segments of this country's business clima'.e, but we in agriculture are
not yet included in this warming trend. These sites chosen for the filth of the
sludge of Eugene are all on cultivated agriculture land. The sites are also close
to small communities of density population. The repugnant, odors, the flies, the
mos:iuito breeding facilities, the rodent problem—all will be paramount health
problems for human and animal residents. The smell of field burning will seem like
Channel #5 compared to what we will have to endure every day of the year from
t hese acres of filthy sludge. There is. not,a knowledgeable individual who will
allow this so-called "fertilizer" (sludge) to dumped on his crop land to poison it
for all time. The pathogens, hard metals, FCBs, put toxins into the soil to be taken
up by plants and thus ingested into the hu7>an body and animals that graz-s the plants..
or eat the products thereof.
There are some .questions we would like to have answered.
. 1. Is it not true the city of Eugene is trying to lure new clean
industry to the area?
2. Would not many of these prospective investors be coming in by
air via the Eugene airport?
3. Would not the airport be-considered Eugene's front door for the
A-110
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Page 2
December 6, 1983:
E.. P. A.
Norma Young
entrance of these visitors?
^.. Why would Eugene want to put a cesspool in its front yard?
These: two proposed dumping sites are within; seeing and smelling distance; of the
npinicipal airport., The choice of eithe^ of the above two sites at Eugene's
front d'oor, in:, our opinion,, surely would raise some doubts as to the ability
of decision makers in charge in our area. None of the points put forth by the
Waste Water lyranagementgroup anc* their engineers have assured us that we do
not have; reason toi be fearful of all the contamination afore mentioned., If
this, group is allowed' to use; this: clean agriculture land for the contaminated
sludge, the potential destruction it will deliver to the land,, water and air
is irrevocable.
It is our earnest hooe,, Ms. Young, that you and your agency will please consider
the fears and plight of all of those who live in ttie areas and pathways of site
C and Prairie Roadv Please do not let them have the land to build the sludge
ponds: on site C and Prairie Road.
Thank you very much.
Res
and Lois J» Schrenk
-------
Chester Swenson
91004 Prairie Rd.
Junction City, Oregon
December .6, 1.985
Ms. Horma Young M/S 445
U.S. E.P.A. Region 10
1200 Sixth Ave,
Seattle, Wash. 98101
Dear Madame:
Concerning the E.I.S. for sludge disposal.
I am opposed to the use of Site C or any adjacent sites.
I don't think any of our 160,000 acres of prime farm land
in Lane County should "be polluted by MWMC.
Why should Federal Funds (our money) be -used .for MWMC'3
sewer, sludge, and industrial waste projects? Is EPA going
to fund a new septic tank for my home? What is the difference?
If not, wouldn't that be discrimination?
Is a Federal balanced budget any concern of EPA?
Is the rest of Eolo statement as misleading as Pye's
statement on page 165?
Y;ours truly,
Chester Swenson.
y^p---•--"-
DEC 8 1983
CWVMWNMENTAL EVAU.iAi.GN
BRANCH
A-112
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Appendix B
Sludge Lagoon Liner
Cost Estimate
-------
Metropolitan
COMMISSION MEMBERS
Christine Larson— Springfield Councilperson
A/2|C'tp\A/£lf>£fcr VH^V.I^LJ LJ Gerald Rust—Lane County Commissioner
Vlanagement
Gary Wright—Lane County Lay Representative
Pat Hocken— Eugene Lay Representative
Betty Smith— Eugene Councilperson
Steve Allen— Springfield Lay Representative
f* f^YY+fri iccifltl Mark Westling—Eugene Lay Representative
225 NORTH 5TH ST. — SPRINGFIELD CITY HALL — SPRINGFIELD, OREGON 97477 TELEPHONE (503) 747-4551
February 21, 1984
Ms. Norma A. Young, Project Monitor
Environmental Evaljwrtion Branch
U. S. Environmental Protection
Agency /-"
1200 Sixtff Avenue, M/S 443
Seattle, WA 98101
SUBJECT: SLUDGE LAGOON LINER COST ESTIMATE
As you verbally requested, enclosed is the order-of-magnitude cost estimate
for lining the facultative sludge lagoons associated with the permanent sludge
management system with the same type of liner as used in the Seasonal Industrial
Wastewater holding lagoons. In using this information, please keep in mind
that this cost estimate is based only on this one type of liner and that use
of a liner of this type in this particular application may in fact be inappro-
priate. Other methods of sealing the lagoons may be better suited and/or
less costly than this option.
The specification of a lagoon liner in the final lagoon design should be the
result of a full scale engineering design effort and based on the performance
requirements of the lagoon. This design effort would include investigation
of several options for lagoon sealing, including possible use of native soil
materials, importation of soil or clay sealant materials, use of various types
of plastic liners, or other options.
Sincerely,
AL PEROUTKA
Civil Engineer
APrbe
Enclosure
cc: Dick Thiel, EPA
Mike Rushton, Jones & Stokes
AP
BCS
DC
B-l
-------
BROWN AND CALDWELL
CONSULTING ENGINEERS
0. H. CALDWELL. PE Chairman
T. V. LUTGE. PE President
E. F. MISCHE. PE Exec Vice Pres
D P NORRIS. PE Vice Pres
February 1, 1984
Metropolitan Wastewater
Management Commission
Suite 292
225 North Fifth Street
Springfield, Oregon 97477 13-112-82
Attention: Mr. William V. Pye
ESTIMATED COST OF PLASTIC LINER FOR SLUDGE LAGOONS
As you requested, I have prepared an order-of-magnitude cost
estimate of a plastic liner for the sludge lagoons associated with
the permanent sludge management system. The cost is based on the
same type of liner used for the Agripac lagoons, and in fact, was
derived using the unit costs associated with the Agripac project.
Our estimate for the liner is $960,000, including engineering and
contingencies, and is based on a Seattle Engineering News-Record
(ENR) index of 4,800. As you know, this type of liner represents
only one of a variety of methods for lining lagoons and is not
necessarily the one we would consider best suited for the permanent
sludge project.
BROWN AND CALDWELL
Steve Krugel
Project Manager
SJK:tab
BROWN AND CALDWELL
P.O. BOX 11680 EUGENE, OREGON 97440
2300 OAKMONT WAY SUITE 100 EUGENE, OREGON 97401 (503) 686-9915
ATLANTA DALLAS-FT. WORTH DENVER EUGENE, PASADENA. ; SACRAMENTO SEATTLE:: TUCSON :: WALNUT CREEK WESTWOOD
B-2
-------
Appendix C
Final EIS
Distribution List
-------
METROPOLITAN WASTEWATER MANAGEMENT COMMISSION EIS DISTRIBUTION LIST
CONGRESSMEN
FEDERAL AGENCIES
STATE AND LOCAL
OFFICIALS AND
AGENCIES
LIBRARIES
Senator Mark Hatfield
Senator Bob Packwood
Representative Jim Weaver
Advisory Council on Historic Preservation
U.S. Department of Agriculture
Soil Conservation Service
U.S. Department of Commerce
National Marine Fisheries
U.S. Department of Defense
Corps of Engineers, Portland District
U.S. Department of Health and Human Services
U.S. Department of Housing and Urban Development
U.S. Department of Interior
Fish and Wildlife Service
U.S. Geological Survey
U.S. Department of Transportation
Federal Aviation Administration
Governor of Oregon
Mayor of Eugene
Mayor Springfield
Mayor of Coburg
Mayor of Junction City
Oregon Department of Environmental Quality
Oregon Land Conservation and Development Commission
Oregon Department of Fish and Wildlife
Oregon Department of Water Resources
Oregon Health Planning and Development Agency
Oregon Department of Transportation
Oregon State Historic Preservation Office
Oregon State Clearinghouse
Lane Council of Governments
Lane Regional Air Pollution Authority
Lane County Health Department
Metropolitan Wastewater Management Commission
Eugene and Springfield Planning Departments
Eugene and Springfield Public Works Departments
Eugene Department of Planning and Community Development
Coburg Chamber of Commerce
Junction City Chamber of Commerce
Eugene Public Library
Springfield Public Library
Junction City Public Library
A list of area residents receiving the Final EIS follows:
C-l
-------
Area Residents
Paul Adams
Agri pac
Claude Allen
Steven J. Allen
Mr. & Mrs. Allison
Arl Altman
Mr. & Mrs. Bud Andrews
Mr. & Mrs. Andrews
Mr. & Mrs. John Ankeny
Mr. & Mrs. Atkinson
Peter V. Baehr
Jerry & Nancy Balding
Melva Barnes
Gary Beck
Dora! G. Bell
Ral Berfory
Glen Berkshire
Richard Beverly
Charles Y. Blaine
Steve & Debra Blexseth
Arnold Bodtker
Mrs. Eugene Bohanan
Bohemia, Inc.
Richard Borgmeier
Katherina E. Bowder
Mr. & Mrs. Darrell Bowes
Kerry Brough
Ms. Dee Brown
Tim A. Brush
Kathleen Bruton
Bob & Jackie Bryson
Jay & Mabel Bugbee
Jud Buttner
Orin Campbell
Edith Carr
Dennis Cartier
Cascade Fiber
Cascade Plating Co., Inc.
Joseph Cersovsici
Mr. & Mrs. P. S. Chambers
Linda Christensen
Jere Christner
Ralph Cleveland
Chris Cogluth
Bob Coller
James L. Conner
William E. Connor
Doug Cook
William & Anita Cook
Steve Cooper
Christina Corelli
J. Covington
Clark W. Cox, Jr.
L. B. Crayton
Jim & Jan Cronk
Gary Cruzan
Ronald Curtright
Dairy Technology
Lynn & Jeffrey Davis
Ruth I. Davis
Eddie De La Vega
Ernie Dennis
Jeno De Piero
Mr. & Mrs. Detato
Donald C. Dickey
Carl Dipaolo
George M. Dipprey
Betty Donaldson
Robert Dooley
Gerald Edwards
D. W. Eisele
Gordon Elliott
Mr. & Mrs. Thomas Ellis
Joyce Engels
Emmet Engeman
Dianna M. Ersinger
Esther R. Everson
Melody Faber
C. C. Fairbanks
Michael E. Farthing
Mr. & Mrs. Robert Farver
Eric Fischer
Mrs. Lyman Fisk
Jack Flint
Jeanette Flynn
I. Forneel
Mr. & Mrs. Herbert Fortner
Faye Foster
Everett Fox
Marl in & Shirley Franssen
Vance Freeman
F. E. Gallaher
Ernest J. Garrett
Howard Gay
C-2
-------
William Gilliam
Earl Gingerich
Kinly Good
Terry C. Gould
Marie Gray
Charles Grimes
Gerald Grimes
Mr. & Mrs. J. E. Grove
Helen & Bob Gwozdz
Mr. & Mrs. David Haag
Mr. & Mrs. K. G. Hagdahl
Rick Hammond
Tim Hanley
Beverly Harper
Warren Harper
Ray Harrison
H. Harrold
Geneva Harwood
Rhonda Harwood
Jon Haterius
Tom & Vora Heintz
Lynn & Ron Heitz
L. Hellwege
David Henderson
Dean Hennigan
Charles Hepner
Rita Hepner
P. Sydney Herbert
Paul Hillwege
Randall Hledik
Pat Hocken
Edward Hoffman
H. L. Hostick
Howard Humphrey, Jr.
Howard Humphrey, Sr.
Liz Hunter
Elmer C. Ingle
J. R. Ireland
Mr. & Mrs. Warren Jacquenod
Derek & Diane Jaros
Richard Jenson
Miriam Jeswine
Al Johnson
Donald L. Johnson
Kimber Johnson
Robert & Bessie Johnson
Coy Jones
Eric Jones
Robin Jones
Dr. William C. Jones
John Jurgens
Jon Kahananui
Bob Kaiser
Donna Kane
Ann & Douglas Kelsey
Donovan Kendall
Lorrayen Kent
Kelly Ketchum
A. J. Ketel
Mr. & Mrs. Clemens Kilwien
Maurice King
Phil L. King
Ed Kinser
Maria Kinser
Daniel & Ann Klemp
Dan Knapp
Bernice Koon
Tim Koon
James Kovack
Steven Krugel
Kathleen Kruse
Mr. & Mrs. J. Kulick
Robert Lacoss
Sharyl LaFleur
Sandra L. Land
Mr. & Mrs. William Land
Christine Larson
W. D. Larson
Larry R. Lee
Sandra & Gary Lee
James M. Lemert
Genna Lemman
Donald & Margaret Lewis
Jim Long
K. Loreman
Darrell Lowery
John Lund
Bill & Nancy MacDowell
Barbara McCormick
Mark Madison
Grace & Raleigh Manley
Bob and Amanda Marker
Stanley Martin
Ben Masengil
Nick & Maurene Maskal
Mr. & Mrs. W. C. Mateson
C-3
-------
Mr. & Mrs. Leonard Mayer
Alton McCully
Jenny McDole
Melvin McNeill
John Mehringer
Jim Melamed
Julian B. Melerdroz
Bob Meltebeke
Richard Meltebeke
Mr. & Mrs. Dave Mills
Michael & Michelle Mi shier
Douglas Melevin
Cheryl Meng
Mr. & Mrs. Ralph S. Metz
James M. Montgomery, Consulting Engrs.
Hal & Patty Moore
Jim & Gladys Murray
Joel A. Naems
John C. Neely, Jr.
Garry Neil
Nola Nelson
Eleanor Newlan
W. L. Nichols
Mr. & Mrs. W. W. Nightingale
Kay Nordlund
Debbie Odell
Larry Odell
Pat Odermann
John C. Ohm
David 01 and
0. L. Olson
Michael J. Oths
Allen Outland
Dr. Robert Packwood
Greg Page
A. B. Palmitessa
Wallace C. Parker
Garry Patterson
Dan & Joan Payne
Roy Pederson
Richard E. Peterson
Mark Phelps
Rick D. Pieper
Tom & Mary Ann Potter
Laurie Power
F. Printz
Ruth Pritchard
Paul & Jonnie Randall
Cheryl Reedy
Rich Reiling
Wes Reimer
Eleanor Reynolds
E. R. Reynolds
Mr. & Mrs. R. Richard
Mr. & Mrs. Herman Ricketts
Rebecca Ricksler
Mr. & Mrs. Ridgley
Michael Rife
Milton W. Root
Curtis Roth
Gerald W. Rust
Everett G. Sanders
Herman & Helen Sanders
Sam Saunders
Don Savoie
Barbie Schmidt
Larry Schoelerman
John G. Scott
Ken E. Scoville
Linda Seals
Jerry Shanbeck
James M. Sniffer
John Shuler
John Siekert
Fred Simmons
Wanda Simmons
Ben Simpson
Betty Smith
Mr. & Mrs. Elroy Smith
Lloyd Smith
Marshall & Alice Smith
W. H. Smith
C. Snellings
El wood Soasey
Ted & Elizabeth Soptelean
Scott Spearman
N. W. Spurgeon
George Steele
Jack Stepp
Nicke Stevenson
William Stevenson
Mike Stoltz
Ruby Stone
Mr. & Mrs. Chester Stoner
John C. Stoner
Dave & Jocelyn Stram
Joel Strandlian
C-4
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Ken & Sylvia Stursa
Beryl Sunderman
Survival Center, Oregon U
Russell E. Svingen
William Swan
Chester Swenson
Vern Swenson
Randy Sweet
Jack Thomas
Carol Thompson
Charles W. Thompson
Lawrence Thorp
Barbara Tooley
Daniel Tucker
Myra Tucker
Mary Tull
Steve A. Tyler
Gene Vaillancourt
Agnes Van Devender
Mark Van Valkenburgh
Edward & Ethel Vogt
Van Volk Residence
Jim Wade
H. H. Waechter
Rod Wagner
Dave Walker
Don Walker
Ray V. Walter
Keith Walton
Dave & Page Walton
Robert D. Warner
D. Michael Wells
Steven Wells
W. Wernicke
Mark Westling
Mr. & Mrs. Mike Westrope
Carl A. Wheeler
Jeff White
Marie Whitson
Steven & Nancy Wilhite
Darin & Monte Wilson
Don Wobbe
John Wofford
Curtis Woodruff
John R. Woodruff
Bill Wooten
Gary Wright
Ken & Judy Wullenwaber
W. R. Yates
Harold Youngquist
Don Ziegler
C-5
* U.S. GOVERNMENT PRINTING OFFICE: 1984 795-611
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